This policy sets out how Klevo handles your personal information and explains the measures we havetaken to make sure we abide by the Privacy Act 1988 (Cth), (Privacy Act) which includes the Australian Privacy Principles. It also aims to answer all the questions you might have about how we collect, hold, use and disclose yourpersonal information. For the purposes of this Privacy Policy, “Klevo’’ or “we” means Fly Wallet Pty Limited, ABN 89 639 905490 ASIC Financial Services License Number 527319.

We may, in connection with particular services offer or provide to you, make other privacy disclosures to you or seek your authority to use your personal information in ways which are different from or more specific than those stated in this Privacy Policy. In the event of any inconsistency between the provisions of this Privacy Policy and those other disclosures, the other disclosures will apply. These principles may not apply to certain records and practices relating to the employment relationship between us and our employees or to certain disclosures between related bodies corporate. It is important that you read and understand this Privacy Policy.

“Personal information” is information or an opinion about a reasonably identifiable individual. The types of personal information that we collect and hold include the information you give us when you make an enquiry, register as a customer or apply for a product, including your contact details and general demographic and financial information.

We also collect and hold information about how you use our products and consume our services, including transaction and payment information, and details of any contact you have with our staff. We may also collect information regarding your internet activity (including your location) when you use our website, mobile app or online services. As a general rule, the collection, holding and use of your personal information will be necessary for us toprovide you with particular services.
This includes:
• assess your application for our products and services
• managing your account
• sending you statements and other information
• letting you know about features, rewards or offers you may be eligible to receive
• responding to your questions
• solving your problems
• knowing what type of services are likely to be useful to you
• verifying your identity
• minimise risks and identify or investigate fraud, possible money laundering or terrorism financing activities or other illegal activities
• to comply with laws and assist government or law enforcement agencies
• develop a better understanding of your needs using information we have about you or our othercustomers (transaction information), data from other sources such as third party websites or theAustralian Bureau of Statistics.
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If you don’t provide us with your personal information or otherwise authorise us to collect this information from third parties, we may not be able to provide you with one or more of our services. We may also use and exchange your information for other reasons where the law allows or requires us to do so Yes, we may also collect your personal information to comply with legislative and regulatory requirements including, but not limited to, those imposed by the:
• Superannuation Industry (Supervision) Act 1993
• Superannuation Guarantee (Administration) Act 1992
• Insurance Contracts Act 1986• Corporations Act 2001
• National Consumer Credit Protection Act 2009
• Anti-Money Laundering and Counter – Terrorism Financing Act 2006

From time to time, we may also use your personal information to let you know about other products and services from Klevo that you might be interested in. We might also want to let you know about products and services from partners and other companies. That’s fine. Just let us know by emailing us at privacy@flywallet.com.au or change your marketing preferences via the Klevo App. If you apply for any of our products and your application is declined, we may keep your details on file to let you know about future products. We will ordinarily collect any information about you directly from you or where it is provided to us with your authority. For example, we collect personal information directly from you through forms you fill out when applying for our products and services, when you make a claim under an insurance policy or through your ongoing interaction with us. When you call us on the telephone, we may monitor and in some cases record the telephone conversation for staff training and record-keeping purposes. Further, when we communicate with you by email, we may use technology to identify you so that we will be in a position to know when you have opened the email or clicked on a link in the email. When you use the Klevo App we may collect information about and/or monitor your activities, transactions, location, and behaviours.

From time to time we may receive information that we have not asked for about you from third parties. We will only keep, use and disclose this information as permitted by law. Further, if personal information about you is collected by third parties on any website you have accessedthrough our websites or mobile app, we may also collect or have access to that information as part ofour arrangement with those third parties. We may also collect basic personal information about third parties (e.g. an employer or a healthprovider) if provided by an applicant or claimant. We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date.

You mayrequest access to the information we hold about you at any time by emailing our Privacy Officer privacy@flywallet.com.au

Under certain circumstances, we may not tell you what personal information we hold about you or allowyou to access thatinformation, for example where the information relates to legal proceedings with you or where we are prevented by law from disclosing the information, or providing access would prejudice certain investigations. If one of the exceptions applies, we will consider whether the use of an intermediary is appropriate and would allow sufficient access to meet the needs of both parties.

Where we do grant access to your information, we may charge you a fee for accessing your personal information. Under the Privacy Act, you also have a right to request that we correct information that you believe to being accurate, out of date, incomplete, irrelevant or misleading. If at any time you believe that personal information that we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please advise us by emailing us at privacy@flywallet.com.au and we will take all reasonable steps to correct the information.

You can ask us to associate with the information held, a statement from you claiming thatthe information is not correct.If there is a denial of access to your personal information or a dispute as to the correctness of any personal information held, we will provide you with reasons for the denial or its refusal to correct the personal information. If you disagree with our decision for the denial or refusal to correct the personal information, you may request that we review the decision via our complaints handling procedures whichare outlined below. We will generally need to know who you are in order to provide you with our products and services. Despite this, in some circumstances you are entitled to deal with us anonymously, or by using a pseudonym (fake name), for example when making general enquiries about the services we offer.

In some circumstances, you may receive a better service or response if we know who you are. For example, we can keep you up-to-date and better understand a complaint you might have if we know who you are and the circumstances of your complaint. You must tell us when you are using a pseudonym when applying for our services. If we need to identify you, we will tell you whether or not your real name is required to access those services.

This statement sets out our current Privacy Policy. It replaces any of our other Privacy Policies which have been issued before the date of this Privacy Policy. We listen to the feedback our customers give us, and also what the broader public has to say about what we do. This informs how we develop new products and services, and also new ways of working. Because of this, our Privacy Policy may need to change from time to time. We encourage you to periodically review our Privacy Policy for any changes. If you have a problem, complaint or dispute Our Service commitment At Klevo we are committed to providing our customers with innovative banking solutions and the best customer service experience. Resolution of problems is a priority for us. If at any time our service does not meetyour expectations we would like you to let us know. How to contact us If you have a complaint, there are a number of ways to contact us:
• Send an email to one of the below:
For service related matters: service@flywallet.com.au

How will your complaint be handled? If we cannot solve your problem on the spot, we will let you know who is handling your complaint andhow long it is likely to take for it to be resolved. For further information about how we handle complaints, ask our friendly staff or download a copy of our Complaint Guide available on our website. What to do if you feel your complaint has not been resolved If you’re unhappy with our response you can approach the Australian Financial Complaints Authority(AFCA). AFCA provides a free and independent complaint resolution service for financial services. To contact them you can:
Call: 1800 931 678 (free call)
Email: info@afca.org.au
Website: www.afca.org.au
Write to: GPO Box 3 Melbourne VIC 3001

You may also elect to contact the Office of the Australian Information Commissioner (OAIC) if you have acomplaint about the way we handle your personal information at:
Office of the Australian Information CommissionerGPO Box 5218, Sydney NSW 2001
Call: 1300 363 992
Email: enquiries@oaic.gov.au Website: www.oaic.gov.au