Privacy Policy

Overview

This website (www.flexipurchase.com) and the services and information available through it ("Service") are provided as part of the expense management and related services that National Australia Bank Limited (“NAB”) and Bank of New Zealand (“BNZ”) (collectively, “Banks”) are providing to your company or organisation ("Company"). The Banks make the Service available to the Company pursuant to an agreement that the Banks have in place with the owner of the technology, the Fraedom Group of companies (“Fraedom Group”).

The purpose of this privacy policy is to provide information about the way data that personally identifies the user or subject of the Service ("Personal Data") is collected and processed in connection with the Service by the Fraedom Group, and how that data may be accessed by NAB or BNZ.

For more information on how NAB handles its customer’s personal information, please visit www.nab.com.au/privacy. For more information on how BNZ handles its customer’s personal information, please visit www.bnz.co.nz/support/banking/privacy-and-security/your-privacy-and-security.

By using this website or the Service or providing the Personal Data, you acknowledge that the Personal Data is being collected, used, disclosed and held in accordance with this privacy policy.

If you are using the Service on behalf of someone else, you must ensure that you have that person’s consent to provide their Personal Data for processing as described in this privacy policy. If you are not certain whether you have such consent, then you must not input any Personal Data in this Service.

If you have any questions regarding the collection and/or processing of the Personal Data, please contact your Business Bank Manager in the first instance.

Except where stated or the context requires otherwise, references in this privacy policy to ‘you’ or ‘your’ are to be taken to include references to the website user and, where applicable, the Company and references to 'us', 'we' or 'our' are to be taken as references to the Fraedom Group and, insofar as your Bank may access Personal Data in the Service, to NAB or BNZ (as applicable).

What Personal Data Is Collected Or Received?

In order to provide the Service and other services required by your Company, certain Personal Data may be required from time to time. This Personal Data may include:

• your name and title;
• your company name and employee ID number;
• your contact information, including your telephone number and email address; and
• your credit card details.

Through the use of cookies on this website, we may collect traffic data or receive information about your use of this website, although the cookies used on this site do not collect information that identifies individual users. Please see the section headed “Cookies” below for further details.

If you do not provide certain Personal Data, you may be unable to use the Service and we may be unable to provide the information or services that you have requested.

How Do We Collect or Receive Personal Data?

We may collect or receive Personal Data directly from your Company or its nominee(s), from you, your administrator or through data submitted to the website or through the use of cookies on the website. We may also collect Personal Data over the telephone, email or internet or when you contact us through the website by using the ‘Contact Us’ facility, the ‘Demonstration Request’ facility or otherwise.

What We Do With Personal Data

We (and those acting on our behalf) may collect, store, use, process and transfer Personal Data across international borders in accordance with this privacy policy in and/or to countries around the world (“Countries”). The main Countries in which the Personal Data may be used and/or disclosed are Australia and New Zealand but other Countries may include the United Kingdom and the United States of America. For a full list of applicable Countries, please see Fraedom’s privacy policy at www.fraedom.com/user_-_privacy_policy.

We (and those acting on our behalf) may collect, store, use and process Personal Data both inside and outside the Countries:

• in accordance with your Company’s written instructions;
• as required to provide the Service;
• in accordance with any terms set out at the point at which Personal Data is collected; and
• as necessary to comply with legal, regulatory or other statutory requirements.

This may include:

• the creation, storage and administration of your expense administration profile;
• the transfer and disclosure of Personal Data to service providers which the Company requires or requests us to provide as part of our provision of services to you;
• the transfer and disclosure of Personal Data to service providers, in and to the Countries, that are relevant to the provision of the Service to you (for example, the provision of IT infrastructure for the logging and management of support queries and for the purpose of optical character recognition associated with the technology we use);
• responding to you or your Company’s requests for information concerning your expense transactions or to respond to questions you or your Company might have;
• the transfer, disclosure and storage of Personal Data of your Company’s registered administrators to enable us to contact them about the Service (for example, to keep them informed about future releases of the technology, the status of support queries that have been logged, advising of upcoming maintenance windows and other issues that may affect the Service);
• addressing questions relating to the Service from you or your Company;
• the transfer and disclosure of Personal Data to the Fraedom Group in any of the Countries;
• the provision to your Company of management information, data aggregation (including aggregation using data provided to us by third parties at your Company’s request), quality assurance surveys and any other services required from time to time by your Company;
• the transfer and disclosure of Personal Data to your Company as required by your Company from time to time, including as part of its management information and expense management monitoring requirements;
• the transfer of data to third parties at your Company’s request;
• responding to an audit of the Service by your Company;
• the detection and prevention of fraud in connection with the Service;
• improving your experience of the website and the Service based on information we collect or receive from the use of cookies (please see the section headed “Cookies” below for further details); and
• the transfer and disclosure of data in and to the Countries to assignees, sub-contractors and advisers of the Fraedom Group from time to time.

In the event of any conflict between any terms set out at the point at which Personal Data is collected and this privacy policy, the terms at the point of collection shall prevail.

General

Cookies

Information collected from cookies and other technologies is used to improve your user experience and the overall quality of the Service. This is done by setting our own cookies but also through certain third party products including FlexiPurchase Session Cookie and FlexiPurchase Language preferences cookie. These third party cookies improve your experience of this website and improve the Service provided through this site. The cookies used on this website do not collect information that identifies individual users.

Location Based Services

Certain Services require details of your location. Depending on your browser and mobile device settings, we may receive this information automatically or following a request which you accept. We may share this data with certain third parties in order to provide these location based services. If you elect to disable location based services, you may not be able to use some or all of the features of the relevant Service.

Accessing the Website using the FlexiPurchase App

If you are a user of the Service, you may use the FlexiPurchase App to access the website and the Service. By registering a mobile device in order to access the website and the Service via this App, you consent to the collection of information about your device’s Operating System (OS) version, manufacturer, model and carrier. This information is used for the duration of your session and is not stored by us.

Accuracy

Please provide accurate Personal Data and update it as necessary in the manner specified below. In the absence of any update, we will assume that the Personal Data submitted is correct.

Right of Access and Correcting your Personal Information

Subject to the provisions of applicable law and for a small fee (where permitted by law), you may obtain copies of the Personal Data (if any) we hold about you by contacting us at the address given below. Additionally, if you wish to correct the Personal Data other than by using the functionality provided on or through the website, please contact us at the address given below.

Security

We recognise the need and take reasonable steps to ensure that Personal Data we have collected remains secure. While we have security measures in place in order to protect against the loss, misuse, alteration of and unauthorised access to Personal Data, you acknowledge that there remains a risk that Personal Data transmitted over the internet and stored by computer may be intercepted or accessed by an unauthorised third party.

Marketing

We will not send you marketing material unless you or your Company has requested it and we will not sell your Personal Data to anyone, or otherwise disclose your Personal Data to any third party except as may be requested from time to time by your Company, as outlined in this privacy policy or as may otherwise be required or permitted by law.

Retention of Personal Data

We are only permitted to retain Personal Data for so long as is necessary having regard to the purpose of the processing. Your Personal Data may therefore be deleted after a reasonable period of time and, where applicable, if you have not used the Service for some time, you may have to re-enter your Personal Data.

Complaints

If you have a comment or complaint about this privacy policy or the manner in which your Personal Data is used, please contact your Bank or the Fraedom Group at the appropriate address set out in the ‘Contact’ section below.

Changes to our Privacy Policy

We may change this privacy policy from time to time without prior notice and will post the updated privacy policy on the website so that you are always aware of what information is collected, how it is used and under what circumstances it may be disclosed.

Contact

Questions and comments regarding this privacy policy should be submitted to us using the website’s ’Contact Us’ facility.

You can contact us by writing to us as follows:

National Australia Bank Limited
Email: client.services@nab.com.au

Bank of New Zealand
Email: bnz.transactional.services@bnz.co.nz

Fraedom Pty Ltd (in Australia)
Level 18
452 Flinders Street
Melbourne
Victoria 3000
Australia
FAO: Legal Counsel
Email: legal@fraedom.com

Fraedom Company Limited (in New Zealand)
Level 7
8 Mahuhu Crescent
Auckland 1010
New Zealand
FAO: Legal Counsel
Email: legal@fraedom.com

Last updated: October 2016