Privacy Policy

Introduction

This Privacy Policy (the ‘Policy’) applies across all websites that we own and operate and all services we provide, including our online products, and any other apps or services we may offer (the ‘Services’). For the purpose of this Policy, this Policy applies to you too. With regard to ‘personal data’ we mean identifiable information about you, like your name, email, address, telephone number, bank account details, payment information, support queries, community comments and so on. If you cannot be identified (for example, when personal data has been aggregated and anonymised) then this Policy does not apply. Recreo may need to update this Policy from time to time. Where a change is significant, we will make sure we let you know – usually by sending you an email. You can read the whole Policy below or go to the section you need by scrolling down.

Who is Recreo?

When we refer to ‘we’ (or ‘our’ or ‘us’ or ‘Recreo’), that means Recreo Financial Pty Ltd and all its wholly owned subsidiaries. Our headquarters are in Australia, but we may operate and have offices in other countries. Address details for all Recreo offices are available on our website. We provide easy-to-use software solutions for superannuation funds and other institutions. At the core of our software is our platform software for superannuation fund members. If you want to find out more about what we do, please see the “About Recreo” page on our website.

Our data protection principles

Our approach to data protection is built around four key principles. They are at the heart of everything we do relating to personal data. Transparency: We take a human approach to how we process personal data by being open, honest and transparent. Enablement: We enable connections and efficient use of personal data to empower productivity and growth. Security: We champion industry leading approaches to securing the personal data entrusted to us. Stewardship: We accept the responsibility that comes with processing and hosting personal data.

How we collect your data

When you visit our website or use our Services, we collect personal data. The ways we collect it can be broadly categorised into the following: Information you provide to us directly: When you visit or use some parts of our website and/or Services we might ask you to provide personal data to us. For example, we ask for your contact information when you sign up for information on our Services, respond to a job application or an email offer, participate in community forums, join us on social media, take part in training and events, contact us with questions or request support. If you do not want to provide us with personal data, you do not have to, but it might mean you cannot use some parts of our website or Services. Information we collect automatically: We collect some information about you automatically when you visit our website or use our Services, like your IP address and device type. We also collect information when you navigate through our website and Services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our website and Services so that we can continue to provide the best experience possible to you. Some of this information is collected using cookies and similar tracking technologies. Information we get from third parties: The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide. Where we collect personal data, we will only process it:

  • to perform a contract with you; or
  • where we have legitimate interests to process the personal data and they are not overridden by your rights; or
  • in accordance with a legal obligation; or
  • where we have your consent.
If we do not collect your personal data, we may be unable to provide you with all our services, and some functions and features on our website may not be available to you. If you are someone who does not have a relationship with us, but believe that a Recreo subscriber has entered your personal data into our websites or Services, you’ll need to contact that Recreo subscriber for any questions you have about your personal data (including where you want to access, correct, amend, or request that the user delete, your personal data).

How we use your data

We use your personal data to operate our website and provide you with any Services you have requested, and to manage our relationship with you. We also use your personal data for other purposes, which may include the following: To communicate with you. This may include:
  • providing you with information you’ve requested from us (like training or education materials) or information we are required to send to you
  • operational communications, like changes to our website and Services, security updates, or assistance with using our website and Services
  • marketing communications (about Recreo or another product or Service we think you might be interested in) in accordance with your marketing preferences
  • asking you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with).
To support you: This may include assisting with the resolution of technical support issues or other issues relating to the website or Services, whether by email, in-app support or otherwise. To enhance our website and Services and develop new ones: For example, by tracking and monitoring your use of the website and Services so we can keep improving, or by carrying out technical analysis of our website and Services so that we can optimise your user experience and provide you with more efficient tools. To protect: So that we can detect and prevent any fraudulent or malicious activity, and make sure that everyone is using our website and Services fairly and in accordance with our Terms of Use. To market to you: In addition to sending you marketing communications, we may also use your personal data to display targeted advertising to you online – through our own website and Services or through third party websites and their platforms. To analyse, aggregate and report: We may use the personal data we collect about you and other users of our website and Services (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties.

How we can share your data

There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:
  • other companies in the Recreo group of companies
  • third party service providers and business partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or Services, or to market or promote our Services to you
  • regulators, law enforcement bodies, government agencies, courts or other third parties where we think it is necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure
  • an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business
  • other people where we have your consent.

International data transfers

When we share data, it may be transferred to, and processed in, countries other than the country you live in – such as to the United States, where applicable. These countries may have laws different to what you are used to. Where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected. For individuals in Europe, this means that your data may be transferred outside of Europe. Where your personal data is transferred outside Europe, it will only be transferred to countries that have been identified as providing adequate protection for European data, such as New Zealand, or to a third party where we have approved transfer mechanisms in place to protect your personal data. For further information, please contact us using the details set out in the Contact us section below.

Security

Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens. For more information about security, please check the Recreo security information on our website.

Retention

The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). We will retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we will make sure it is deleted or anonymised.

Your rights

Your personal data has certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the unsubscribe instructions contained in the marketing communication or send your request to privacy@Recreo.com.au. You also have rights to:
  • know what personal data we hold about you, and to make sure it is correct and up to date
  • request a copy of your personal data, or ask us to restrict processing your personal data or delete it
  • object to our continued processing of your personal data.
You can exercise these rights at any time by sending an email to privacy@Recreo.com.au. If you’re not happy with how we are processing your personal data, please let us know by sending an email to privacy@Recreo.com.au. We will review and investigate your complaint and try to get back to you within a reasonable time frame. You can also complain to your local data protection authority. They will be able to advise you how to submit a complaint.

How to contact us

We are always keen to hear from you. If you wish to know what personal data, we hold about you or you have a question or feedback for us on this Policy, our website or Services, please contact us. As a digital technology company, we prefer to communicate with you by email – this ensures that you are put in contact with the right person, in the right location, and in accordance with any regulatory time frames. Our email address is privacy@Recreo.com.au.

Recreo Office

Head Office
Level 13, Australia Square Plaza
95 Pitt Street, Sydney NSW 2000

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