Privacy Policy

1. Our Commitment to Privacy

1.1 At FUNDiMO, privacy is at the core of everything we do. We've built our platform with a privacy-first approach, using FUN IDs so that your personal information stays private.

1.2 This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the FUNDiMO platform.

1.3 By using FUNDiMO, you consent to the practices described in this policy.

2. FUN ID Privacy Protection

2.1 Your FUN ID is a unique three-word identifier that represents you on the FUNDiMO platform (e.g., "horse.green.hope").

2.2 Businesses interact with your FUN ID rather than your contact details. This means:

2.2.1 Businesses never see your email address, phone number or bank details. A business you pay, or that sends you a request to pay, sees your FUN ID and your name. That includes a business that sends a request to pay to your email address, which reaches your FUNDiMO account.

2.2.2 You can receive discounts without giving a business your contact details.

2.2.3 You choose which businesses you pay, link your account to or follow.

2.3 Anyone who has your FUN ID can see your first name, and a business you pay, or that sends you a request to pay, also sees your full name. Your FUN ID does not show anyone your email address, phone number or bank details.

3. Information We Collect

3.1 Account Information

3.1.1 When you create an account, we collect:

3.1.1.1 Email address (for account verification and communication).

3.1.1.2 Your name, and your phone number where your bank or another Data Provider confirms it to us through the Digital ID Network (section 15), or where you add it to your profile.

3.1.1.3 Banking information — your BSB and account number, or PayID. When you save a preferred payment method, we store these details encrypted at rest and use them to set up payments when you link to a merchant; you can view or remove them at any time.

3.1.1.4 Identity documents (for example a driver's licence or passport) when required to verify your identity. We ask for your express consent at the time, separately from your acceptance of these policies, before any identity document detail is submitted for an electronic check. If you do not consent, an alternative way to verify your identity is available to you.

3.1.1.5 Passkey credentials (stored securely for passwordless authentication).

3.2 Transaction Information

3.2.1 We collect transaction data to provide our services, including:

3.2.1.1 Payment amounts and timestamps.

3.2.1.2 Merchant information.

3.2.1.3 Discounts applied.

3.2.1.4 Transaction reference identifiers.

3.3 Usage Information

3.3.1 To improve our service, we collect information about how you use FUNDiMO:

3.3.1.1 Pages visited and features used.

3.3.1.2 Businesses and products you follow or save.

3.3.1.3 Search queries and preferences.

3.3.1.4 Device information and browser type.

3.4 Business Information

3.4.1 For business accounts, we additionally collect:

3.4.1.1 Business name and trading name.

3.4.1.2 Australian Business Number (ABN).

3.4.1.3 Business address and contact details.

3.4.1.4 Bank account details for settlement.

3.4.1.5 Information about the owners of the business: the name, date of birth, residential address and telephone number of each owner who verifies their identity, confirmed through the Digital ID Network (section 15) or given to us directly, and, where an owner verifies with a photo of an identity document instead, that photo, which our staff review.

4. How We Use Your Information

4.1 We use your information to:

4.1.1 Provide and improve our payment and marketplace services.

4.1.2 Process transactions.

4.1.3 Send you notifications about discounts and offers (if you opt in).

4.1.4 Detect and prevent fraud and unauthorised activity.

4.1.5 Comply with legal obligations and regulatory requirements.

4.1.6 Respond to your enquiries and provide customer support.

4.1.7 Analyse usage patterns to improve the platform.

4.2 We will not use your personal information for purposes other than those described in this policy without your consent.

5. Information Sharing

5.1 We are committed to keeping your information private. We:

5.1.1 Never sell your personal information to third parties.

5.1.2 Share your FUN ID and your name with a business you pay or that sends you a request to pay, and never your email address, phone number or bank details.

5.1.3 Disclose personal information to our payment provider, which processes PayTo agreements and account payments for FUNDiMO. We give the provider your name and email address, and your date of birth and residential address if we hold them, the first time you save a bank account, link your account to a business for payment or we set up payments for you, and again when they change because you verify your identity as an owner of a business, your Data Provider confirms a new email address to us, or we correct them for you; we give it your BSB, account number and account holder name when you save a bank account, and your BSB and account number, or your PayID, together with the account holder name, when you link your account to a business; and we give it the details of each payment it processes for you. For a business account we also give the provider the business name, ABN, business address and contact phone number, and the name, email address, date of birth and residential address of the person who represents the business, where we hold them. The provider handles that information under its own privacy policy, and uses it not only to process payments but also to verify identity, meet its anti-money-laundering obligations as a reporting entity regulated by AUSTRAC, and assess fraud and financial crime risk.

5.2 We may share information in the following circumstances:

5.2.1 With service providers who assist in operating the platform (under strict confidentiality agreements).

5.2.2 When required by law, regulation, or legal process.

5.2.3 To protect the rights, property, or safety of FUNDiMO, our users, or the public.

5.2.4 In connection with a merger, acquisition, or sale of assets (with notice to you).

6. Your Privacy Rights

6.1 You have the right to:

6.1.1 Access the personal information we hold about you.

6.1.2 Request correction of inaccurate information.

6.1.3 Request deletion of your account and data (subject to legal retention requirements).

6.1.4 Opt out of marketing communications at any time.

6.1.5 Control your notification preferences.

6.1.6 Request a copy of your data in a portable format.

6.2 To exercise these rights, contact us at privacy@fundimo.com.au.

6.3 We will respond to your request within 30 days.

7. Data Security

7.1 We implement industry-standard security measures to protect your information:

7.1.1 Encryption of data in transit using current industry-standard transport security (TLS).

7.1.2 Encryption of data at rest using AES-256.

7.1.3 Payments processed through PayTo by an Australian payment provider, under its own security controls.

7.1.4 Regular security audits and penetration testing.

7.1.5 Strict access controls for our team (role-based access).

7.1.6 Passkey sign-in for our administration console, with password sign-in refused for any administrator who has enrolled a passkey.

7.2 While we take all reasonable precautions, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

8. Data Retention

8.1 We retain your personal information for as long as necessary to provide our services and comply with legal obligations.

8.2 Specific retention periods:

8.2.1 Account information: retained while your account is active, plus 7 years after closure.

8.2.2 Transaction records: retained for 7 years (as required by Australian tax law).

8.2.3 Usage data: retained while your account is active and after it is closed. We do not currently anonymise it.

8.2.4 Identity verification records for business owners: when you verify your identity as an owner of a business, we keep a record of each verification (when it happened, through which Data Provider, the identifier that Data Provider gave us for you, and the IP address you used), a record of each time you chose, or were sent to, another way of verifying and why, and any photo of an identity document you gave us. We keep them for at least 7 years, including after the rest of your account information has been deleted.

8.3 You may request deletion of your data earlier, subject to legal retention requirements.

9. Cookies and Tracking

9.1 We use cookies and similar technologies to improve your experience:

9.1.1 Essential cookies: Required for login, security, and basic functionality.

9.1.2 Analytics cookies: Help us understand how you use our service.

9.1.3 Preference cookies: Remember your settings and preferences.

9.2 You can control cookie preferences through your browser settings.

9.3 Disabling essential cookies may prevent you from using certain features of the platform.

10. Children's Privacy

10.1 FUNDiMO is not intended for children under 18.

10.2 We do not knowingly collect information from children.

10.3 If you believe a child has provided us with personal information, please contact us immediately at privacy@fundimo.com.au.

11. International Data Transfers

11.1 Your data is primarily stored and processed in Australia.

11.2 Our payment provider may disclose personal information we give it to recipients overseas, including in the Philippines, New Zealand, the United States of America and South Africa. Some service providers may process data in other countries. In these cases:

11.2.1 We ensure appropriate safeguards are in place.

11.2.2 We take reasonable steps to ensure an overseas recipient does not breach the Australian Privacy Principles in relation to your information, as APP 8.1 requires, and we remain accountable under the Privacy Act if it does.

12. Changes to This Policy

12.1 We may update this privacy policy from time to time.

12.2 We will notify you of significant changes by email or through our app.

12.3 The "Last updated" date at the top of this page indicates when the policy was last revised.

12.4 Your continued use of the platform after changes take effect constitutes acceptance of the updated policy.

13. Contact Us

13.1 If you have questions about this privacy policy or your personal information, please contact us at:

Privacy Officer: privacy@fundimo.com.au
General Support: support@fundimo.com.au

13.2 We aim to respond to all privacy enquiries within 30 days.

14. Australian Privacy Principles

14.1 FUNDiMO complies with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).

14.2 For more information about privacy in Australia, visit the Office of the Australian Information Commissioner at www.oaic.gov.au.

14.3 If you are not satisfied with our response to a privacy complaint, you may lodge a complaint with the OAIC.

15. Digital ID Platform

15.1 FUNDiMO takes part in the ConnectID Digital ID Network, which lets an organisation you already deal with (usually your bank) confirm who you are to us. Where we offer it, the network also lets you verify with an identity document at an identity service provider that takes part in it, which then confirms who you are to us. In this policy we call that organisation, or that provider, a Data Provider.

15.2 We collect personal information about you from a Data Provider through the Digital ID Network only with your express consent, given at the time and for that purpose. What we ask for depends on what you are doing with us:

15.2.1 When you create an account, we ask for your given name, your family name and your email address, and your telephone number if your Data Provider holds it and you choose to share it.

15.2.2 When you verify your identity as an owner of a business registered with us, we ask for your given name, your family name, your date of birth, your residential address and your telephone number. Where you verify with an identity document, your residential address and telephone number are optional, and if we do not receive a residential address we can use, we ask you for it.

15.2.3 We ask for nothing else.

15.3 If you do not consent, no personal information is collected about you this way, and an alternative way to verify your identity is available to you.

15.4 We use and disclose what a Data Provider confirms for the purpose you consented to. When you create an account, that purpose is verifying your identity so you can open and use a FUNDiMO account. When you verify your identity as an owner of a business, it is verifying your identity for that business and for your own FUNDiMO account: we keep what your Data Provider confirms in your customer record, record your identity as verified, and give your name, date of birth and residential address to our payment provider, which verifies your identity too, as clause 5.1.3 describes. We use or disclose it for a secondary purpose only where you consent to that further use, or where we are required or permitted by law.

15.5 We may disclose your personal information to a Data Provider in connection with a security or data incident, for the sole purpose of preventing or responding to cyber security incidents, fraud, scam activity or identity theft.

15.6 The operator of ConnectID, which is part of the Australian Payments Plus (AP+) group, and each Data Provider handle your information under their own privacy notices, which are not ours. Clause 6 of this policy explains how to ask us for access to, or correction of, the personal information we hold about you, including anything a Data Provider confirmed.

15.7 We keep the details a Data Provider confirms in your customer record. You cannot change them yourself in your account. If one is wrong, you can ask us to correct it under clause 6, and you will usually also need to ask your Data Provider to correct its own records.