Privacy and Cookies Policy

Version 1, effective 11/12/2019

ClearScore Australia Pty Ltd (ABN 21 624 386 330) and its related and associated bodies corporate ( us, we, our ) maintain a policy of strict confidence concerning your ( you, your ) personal information ( Privacy Policy ). This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) ( Privacy Act ). ClearScore Australia Pty Ltd will be the data controller for the data that you provide us or we collect in relation to the provision of our services to you. We want you to be informed and empowered with respect to your privacy when you use our services. Please read this Privacy Policy carefully before using our website or apps or registering to use our services. Together with our Terms and Cookies Policy, this Privacy Policy sets out our practices regarding your personal data and how we collect, process and treat it.

By visiting www.clearscore.com/au/ ( Site ) and using our apps and services you are accepting and consenting to the practices described in this Privacy Policy. This Privacy Policy applies to information provided to us whether via this Site or any other means and demonstrates how we will comply with the Australian Privacy Principles under the Privacy Act.

References to our website include references to our apps.

Privacy Policy

Cookies Policy

The information we collect

We collect and process information which:

  • you give to us when you register with us, such as your name and contact details
  • we obtain from Credit Reporting Bodies on your behalf
  • we collect about you based on your use of our website or from your mobile device if you are using our app
  • we receive from other sources, such as third parties who give us information about you
  • is collected from cookies.

Information you give us. You may give us information about you when you use our services or by communicating with us. This includes information you provide when you participate in discussion boards, answer specific questions on our website, provide us with feedback, participate in surveys, and when you report a problem.

The personal information you give us may include:

  • Title
  • Name
  • Income
  • Email address
  • Date of birth
  • Phone number
  • Monthly expenditure
  • Residential details
  • Employment details
  • Address history
  • Bank details
  • Property value
  • Deposit amount
  • Monthly rental income
  • Mortgage details
  • Driving licence details
  • Energy and gas tariff details
  • Lifestyle information

Information we collect from Credit Reporting Bodies on your behalf. If you register to use our services, we will obtain your credit score and credit report from one or more Credit Reporting Bodies on your behalf.

Information we collect about you based on your use of our website or apps. Each time you visit our website or use our app we may automatically collect the following information:

  • technical information, including the Internet protocol (IP) address, your login information, browser type and version, time zone setting, operating system and platform
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number

Information we receive from other sources. We may receive information about you if you use any of the websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, service providers, advertising networks, analytics providers, search information providers, social media) and may receive information from them, such as your credit report information, whether or not you have taken out a product with them, what other products you may have used, and other such details.

Information collected from cookies. We and our service providers collect information about your use of our website from cookies. For more on how we use cookies and how to decline them or turn them off please read our Cookies Policy.

Recording telephone calls and other communications. We may monitor or record telephone conversations or other communications between you and us.

How we use the information

We use information we hold about you to provide our services to you and improve those services, administer your account and communicate with you and to use information on an anonymous basis for research, profiling and analytical purposes.

Information you give to us or we collect from Credit Reporting Bodies or other third parties on your behalf as part of our services. We will use this information to:

  • administer your account and relationship with us and to, communicate with you by telephone, mail, email, text (SMS) message or other electronic means
  • verify your identity as part of our identity authentication process
  • provide you with information, products and services
  • where you have provided your consent for us to market to you, provide you with information about other products and services we feel may interest you or be best for you
  • notify you about changes to our services
  • ensure that content from our website is presented in the most effective manner for you and your device
  • aggregate it on an anonymous basis with other data for data analytical and reporting purposes
  • undertake analysis and profiling of your credit information in order to identify and inform you of credit products that we consider are likely to interest you or be suited to your credit circumstances or to enhance our services.

Information we collect about you based on your use of our website. We will use this information:

  • to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • to improve the service we offer you such as understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you
  • as part of our efforts to keep our website safe and secure and to prevent fraud
  • to make recommendations about products or services that may be of interest

Information we receive from other sources. We may combine this information with information you give to us and use this information and the combined information for the purposes set out above.

Recording telephone calls and other communications. We will use telephone recordings or transcripts of communications to check your instructions to us, analyse, assess and improve our services, for training and quality purposes and for the purposes of investigating any complaint you may make, or as evidence in any dispute between you and us.

What we will never do. Rest assured, we will never sell your information to third parties.

Who we may share your data with

We may share your data with other members of our group and with other third parties, such as our service providers, advertisers, Credit Reporting Bodies and fraud prevention agencies.

We may need to disclose your data to others to ensure the smooth provision to you of the products, services and information you request. Your data may be disclosed to the other entities as described below.

These third parties act on our instructions and are processors of your information.

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.

Subprocessors we may share your information with include the following entities:

Entity Name

Activities

Amazon Web Services, Inc.

Cloud Service Provider

Blueshift, Inc.

Customer Relationship Management Provider

Domo, Inc.

Data Storage and Analytics Provider

RateCity Pty Ltd.

Financial Product Aggregator

Segment.io, Inc.

Data Segregation Tool Provider

Vix Verify Pty Ltd.

Fraud Prevention Tool

Zendesk, Inc.

Customer Support Provider

Group company. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

Selected third parties. We may also share your information with selected third parties including:

  • Credit Reporting Bodies, to obtain your credit score and credit report on your behalf and to provide our services to you (please see "Credit Reporting Bodies" below for more detail)
  • Fraud prevention agencies, to prevent crime and trace those responsible (please see "Fraud Prevention Agencies" below for more detail)
  • Product providers, such as our business partners who offer you credit cards, loans, car finance, mortgages, insurance, pensions, investments and other related products, to:
    • assess whether you are an existing customer and for fraud prevention purposes
    • conduct analysis to provide you with better products and services in the future, and for segmentation purposes
    • pre-fill an application form with the product provider
    • assess your probability of being accepted for a product

The product provider does not have permission to use this data for any other purpose including marketing

  • Service providers we use (such as comparison sites and aggregators) for analysis and profiling of your credit information (and any other data provided by you or on your behalf) to identify and inform you of credit products that are likely to be suited to your credit circumstances through targeted advertising. When you click to search for credit offers on our website or our apps, these service providers will record an access by you on your credit file, but this record will be invisible to other lenders, so by itself it will not affect their lending decision and it will not affect your credit score. You can opt out of this if you want to in your "My Account" section, however, if you do opt out of this, we will not be able to show you ads that are specifically targeted to you and will only be able to show you generic ads, which may not be suited to your credit circumstances
  • advertisers that require data, to perform services on our behalf, including selecting and serving relevant adverts
  • analytics and search engine providers that assist us in the improvement and optimisation of our service
  • if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets (or the buyer or seller's advisers)
  • if we or part or all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of ClearScore Australia Pty Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Credit Reporting Bodies. If you register to use our services we will obtain on your behalf, in accordance with our Terms, copies of your credit report and credit score from designated Credit Reporting Bodies. In order to provide these services to you, we will share your information with such Credit Reporting Bodies.

The information which we provide to the CRA may be supplied by them to other organisations such as Fraud Prevention Agencies and used by those organisations for the purposes of checking identity, preventing fraud, tracing and collection of debt. The CRA may also use the data to undertake statistical analysis.

If you choose to apply for a product, the lender may undertake a full credit check and provide you with further privacy information for that product. More information about each CRA and what it does with personal data is available here.

Fraud Prevention Agencies. We will share your personal information with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

Why are we using this information?

We make sure we have your consent to collect, use and share data about you. If you have any questions about the purposes for which we collect and use your personal data, you can contact our Data Protection Officer.

We use your information where you have given us your consent or where use is necessary for the performance of a contract with you (such as delivering our core services to you) and our own legitimate interests.

Performance of a contract. We need you to give us the information you provide, and to collect information about you from the Credit Reporting Bodies or other third parties in order for us to provide you with our services as agreed in our contract with you. We cannot provide our services to you without collecting the information you give us because we need certain information from you to be able to seek your credit report and score and to show suitable financial offers to you.

For other types of information (such as the information we collect based on your use of the website and information we receive from our sources about you), we process this information for the purposes of providing our services to you as agreed in our contract and for the purpose of to enable us to:

  • provide a secure website to our customers; and
  • analyse our users' behaviour and preferences, and information collected from users' devices in order to have information required to be able to improve the services we provide to our customers and the user experience on our website.

Consent. We will always seek your consent to process your information. You have the right to withdraw or decline your consent at any time.

Our Legitimate interests. We may process your personal data for the purposes of our legitimate interests or for the legitimate interests of our product providers or other suppliers. As an example, we may process your personal data to:

  • display tailored product offers to you
  • comply with laws that apply to us
  • provide you with our service, including for the purpose of quality control and analysis
  • protect you and us from fraud or other threats
  • conduct analysis, segmentation and profiling of your data in order to provide you with direct marketing communications
  • improve our service and manage our customer relationships

Direct marketing and how you can change your preference

We offer you the opportunity to receive marketing information from us. You can opt out easily of receiving marketing from us at any time.

We will normally send direct marketing by email if we have your email address, but may choose to contact you via other methods.

You may receive the following types of communications from us:

  • Product recommendations- we'll get in touch with personalised, timely product recommendations that can help you improve your financial situation. We will only ever send these if you explicitly consent to receiving them and you can unsubscribe whenever you like.
  • Content communications- we'll send you content such as tips, research, features and news, coaching programmes on how to keep on top of your money and other related content. You can unsubscribe from these at any time and we will never spam your inbox.
  • Core communications– we will send you your credit report every month, security alerts pertaining to your ClearScore account, significant changes which may impact our service and other such related content. These communications are an intrinsic part of owning a ClearScore account and cannot be opted-out of.

If you would like us to stop sending direct marketing to you, we offer simple ways to do this. Whenever you receive direct marketing you will be given an option to unsubscribe. You may also update your preferences here.

You can also tell us that you do not wish to receive any more marketing communications at any time by writing, with your full name, address and other contact details (to enable us to find your records), to help@clearscore.com.au

How we keep your information secure

We take the security of your data very seriously and use strict procedures to protect it. Whenever we transfer personal data outside of Australia, we ensure that appropriate safeguards are in place to protect the data.

All information you provide to us is stored on our secure servers.

We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.

If we or our service providers transfer personal data outside of Australia, we consider these service providers are bound to legislation similar to the APPs and we have a contractual mechanism with them to enforce your rights.

Part of our customer services function is based in India. We have put in place safeguards to protect personal data processed in or accessed from India.

If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy or de-identify your personal information, in accordance with our document and information retention policy.

Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Act requirements.

How long will we keep your information?

While your account remains active, we keep your information for no longer than is necessary depending on the purpose for which we are using it.

How long we keep your information will depend on the purpose for which we use it. While you are a customer of ours, we will only retain your information for as long as is necessary for those purposes.

After termination of your account, we may continue to use anonymised data (which does not identify individual users) which is aggregated with anonymised data of other users. We use this aggregated anonymised data for data analysis, profiling and research purposes, for example to gain insights about our users. We may also keep your email address to ensure that you no longer receive any communications from us as well as your name, date of birth and latest address for fraud prevention purposes and for the exercise or defence of a legal claim.

Links to and from third party websites

If you follow a link to or from our website to a third party website, please be aware that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies.

Your rights

You can exercise specific rights with regards to the data that we hold about you.

We will provide you with the necessary tools and contact details to be able to exercise your statutory rights regarding the information that we hold about you. You will be able to:

You can ask for access to the personal data that we hold about you so that you can check that we are using your information in accordance with this policy.

You will also usually be able to amend any information that we hold about you that is inaccurate or incomplete through the settings in your account.

For the exercise of any of your rights, you can also contact us at help@clearscore.com.au.

Changes we make to our Privacy Policy

We may vary the terms of this Privacy Policy at any time.

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where we decide it is appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy.

Contacting us and complaints

You can address any questions, comments, complaints or requests regarding this Privacy Policy to the Data Protection Officer at help@clearscore.com.au

If you have a complaint you must send it to us in writing and we will deal with it within a reasonable timeframe, usually 30 days. If you are not happy with our response you may make a complaint to the regulator, the Office of the Australian Information Commissioner. More information is available at:

ClearScore Cookies Policy

Overview of our Cookies Policy

ClearScore uses cookies for a variety of purposes, including ensuring that our website functions as expected, remembering your preferences and gathering data on the users of our website and our services.

By using our website (through any device) you agree that this Cookies Policy, together with our Privacy Policy and Terms, applies to that use. References to our website below include references to our apps.

We are committed to protecting you and any information (anonymous or otherwise) that we collect about you online. This section tells you about how and why we use cookies, and how this allows us to improve our service.

If you wish to use our website, but would like us not to set cookies in your browser, you can disable or remove the cookies. Details on how to do this are set out below. Please note that disabling or removing the cookies we or our third party service providers set may impact the functionality and security of our website and our ability to provide our services to you.

We reserve the right to make changes to our Cookies Policy. Any changes we may make to our Cookies Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Cookies Policy. Your continued use of our website is taken as your agreement to any such changes.

What are cookies?

Cookies are files containing small amounts of information downloaded to your device. We and our third party service providers use both session cookies and persistent cookies. We use cookies for a range of purposes, including to remember any preferences you've set and to improve usability of the website for you and other users.

Cookies are files containing small amounts of information which are downloaded to the device you use when you visit a website. Your web browser (such as Internet Explorer, Mozilla Firefox, Google Chrome or Safari) then sends these cookies back to our website or application on each subsequent visit.

We and our third party service providers use the information we obtain about you through the use of cookies for the following purposes:

  • to recognise your device(s) when you visit our website and to remember if you've set any preferences on our website. This enables us to personalise our content for you and greet you by name

  • to temporarily store data as part of, for example, customer surveys

  • to test new content and evaluate its effectiveness

  • to remember if you've been informed of our Cookies Policy, Privacy Notice and other Terms before

  • to recognise and count the number of visitors to our website and see how you navigate our website when you are visiting it (including tracking page usage and paths used by visitors through our website; and tracking use of our Internet banner advertisements and other links from our marketing partners' websites to our website)

  • to improve our website's usability and keep our services easy to use and up to date

  • to allow you to share pages with social networks such as LinkedIn, Facebook and Twitter / to support social media components, like Facebook or Twitter (where our website uses a plugin from these third party platforms)

  • to ensure you don't miss information that is relevant to you (including targeting our website content, targeting our marketing campaigns and direct marketing emails, targeting our Internet banner advertisements on our website and on other websites)

  • to analyse use of our website (including for performance and statistical analysis, sales and marketing research). To stop us setting these cookies you will need to set up your browser to reject all cookies (see further below)

We may also combine this web usage data with other information we have collected about you. We store this information so that we have a better and more specific understanding of the way users are using our website, and their preferences and interests, for the purposes set out above.

Cookies may be either "persistent" cookies or "session" cookies, depending on how long they are used.

Persistent cookies remain on your device after you have closed your browser, and allow a website to remember your actions and preferences. They are activated each time you visit the website where the cookie was generated. Sometimes persistent cookies are used by websites to provide targeted advertising based on the browsing history of the device. They are stored by the browser and remain valid until their set expiry date (unless deleted by the user before the expiry date).

Session cookies only last for the duration of your visit and are deleted when you close your browser. They facilitate tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.

Many of the cookies we use are session cookies. For example, they help us to ensure the security of your session, and can also keep you signed in to your ClearScore account while you move between pages.

More about the cookies we use

This section describes more about the different types of cookies we use. The cookies are both cookies that we set (first party cookies) and cookies that are managed for us by third parties.

Whether a cookie is a first or third party cookie depends on which website the cookie comes from.

First party cookies are those set by or on behalf of the website visited. All other cookies are third party cookies.

Third party cookies: In some cases, some of these cookies are managed for us by third parties, but we don't allow the third party to use the cookies for any purpose other than those listed above.

Web analytics services: In order to keep our products and services easy to use and up-to-date, we also use web analytics services to help us understand how people use our website. For example, we can see which parts of our services are most popular, identify when errors occur and test different versions of a page or feature to see which one works best. These web analytics services may be designed and operated by other companies on our behalf. They do this using small invisible images known as "web beacons" or "tracking pixels" that may be included in the digital products and services on our website.

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. We use retargeting and online behavioural advertising to market ClearScore which employs targeting cookies to deliver you more targeted advertising.

You can read more about the cookies we and our trusted service providers use below.

By using our website, you agree that we can place both first party and third party cookies and web analytic services on your device.

Specific cookies we use

Below is a full list of the cookies we use together with a description of what they are used for, and whether they are 'first' or 'third' party. Where a cookie is a third party cookie, please visit the providers' website for more information.

Cookie

Cookie Name or Type

Duration

Description

ClearScore

CS_SESSION

Session (30 minutes)

This is a first party cookie allowing users to log into the site when changing page or returning to the site.

CS_PERSON

Session (30 minutes)

This is a first party cookie providing unique tracking for users and allowing tracking across services.

CS_TRACK_FIRST

Session (30 minutes)

This is a first party cookie used to provide a better customer experience, track first time visitors and calculate marketing performance.

CS_ACCEPT_COOKIES

Persistent (30 minutes)

This is a first party cookie used to record user cookie preferences and stop displaying the banner.

CS_VISITED_SITE

Persistent (1 year)

This is a first party cookie used to identify returning users over a long period of time.

ab-[Option]

Session (30 minutes)

This is a first party cookie used to track for internal ab testing of products.

Third Party cookies - These are third party cookies used to track visitors, collect information about how visitors use our site and improve site performance. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the website from and the pages they visited.

Cookie

Cookie Name or Type

Duration

Description

Blueshift

_bs

Session (30 minutes)

This is a third party cookie used for tracking marketing performance and behaviour.

Various

_uetsid

Session (30 minutes)

This is a third party cookie used for analytics and performance tracking.

Google doubleclick.net

Id or IDE

Persistent

This is a third party cookie used to make advertising more engaging to users and more valuable to advertisers.

DSIS

Persistent

This is a third party cookie used to make advertising more engaging to users and more valuable to advertisers

Google Tag Manager

_ga

Persistent (2 years)

These are third party cookie used for Google Analytics and pay per click tracking

_gid

Persistent (2 days)

Cloudflare

_cfduid

Persistent (30 days)

This is a third party cookie used for locally storing certain assets of the site once they are displayed for the first time, which will allow those assets to be displayed quicker in subsequent instances.

SessionCam

sc.Status

Session (30 minutes)

These are third party cookies used for real user monitoring of user experience (these cookies are only applied to a certain percentage of randomly selected users to the site). None of the information inputted by users to the website is collected by the cookie.

sc.ASP.NET_SESSIONID

Session (30 minutes)

Sc.UserID

Persistent (1 year)

Periscopix

AdWords (Google Remarketing Tag)

Persistent (active for 180 days, but can be extended to 540 days)

These third party cookies allow to entice visitors back to the site by presenting targeted advertising

Bing (UET tag)

Persistent

This third party cookie allows for both remarketing and conversion tracking purposes to aid ad performance

Kissmetrics

Kvcd

Session cookie (30 minutes)

These are third party cookies used to track visitors and collect information about how visitors use our site.

km_ai
km_lv
km_ni
km_uq
km_vs

Persistent (5 years)

Km_vs

Session cookie (30 minutes)

Turning cookies off

You can reject cookies within your browser, but please note that certain parts of our website may no longer function as expected.

In all modern browsers you may elect to reject cookies and/or enable do not track features, and we provide instructions on how to do this below. Please note however that by doing so parts of our website may no longer function as expected. For example, if you delete cookies any preferences they record will be lost. This includes for example where you have opted out from cookies, as this requires an opt-out cookie to be set.

If your concerns are based around third party cookies, then we recommend you just reject those cookies, rather than all cookies so that we can still provide you with the functionality you expect.

If you do wish to stop your browser from accepting cookies, see the following pages:

Contact Us

If you have any questions about our cookies or this Cookies Policy, please contact us on privacy@clearscore.com.au