This Privacy Policy explains how Bundle Services Pty Ltd (41 689 011 087) trading as Keel Money ("Keel", "Keel Money", "we", "our", "us") collects, uses, stores and discloses your personal information.
We are committed to protecting your privacy and handling your information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
By using our services, you consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.
1. Information We Collect
We may collect the following types of information:
1.1 Personal Information – such as your name, date of birth, residential address, email address, phone number, and identity documents.
1.2 Financial Information – including your bank account details, biller details (e.g. BPAY codes, account numbers), and transaction history.
1.3 Usage Information – information about how you use our app and services, including device information, IP address, browser type, and access logs.
1.4 KYC/AML Information – additional identity, verification and risk information required to comply with anti-money laundering and counter-terrorism financing obligations.
2. How We Collect Information
2.1 We collect personal information directly from you when you register, provide biller details, verify your identity, or contact us.
2.2 We may also collect information from third parties, including:
- Payment providers (e.g. Monoova, BPAY, banks);
- Identity verification providers (e.g. FrankieOne); and
- Publicly available sources where permitted by law.
3. How We Use Your Information
We use your information to:
- Provide our services, including Smart Contributions and bill payments;
- Verify your identity and comply with legal obligations (KYC/AML);
- Process transactions through third-party providers;
- Communicate with you regarding your account, services, or support;
- Improve and develop our services, app and security measures;
- Detect and prevent fraud, unauthorised use or illegal activity.
We will not use your information for purposes other than those stated above without your consent, unless permitted by law.
4. Disclosure of Information
We may disclose your information to:
- Third-party payment providers and financial institutions (for processing contributions and payments);
- Identity verification and compliance service providers;
- Regulatory and law enforcement bodies where required by law;
- Our professional advisers (legal, financial, compliance);
- Service providers who assist in operating our app, IT systems and customer support.
We will not sell your personal information to third parties.
5. Storage and Security
5.1 Your information is stored securely using AWS cloud infrastructure with encryption and access controls.
5.2 We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification, or disclosure.
5.3 However, no system is completely secure, and we cannot guarantee absolute security of your data.
6. Overseas Disclosure
Some of our third-party service providers may store or process information overseas. Where this occurs, we take reasonable steps to ensure those providers comply with Australian privacy laws or equivalent protections.
7. Access and Correction
7.1 You may request access to the personal information we hold about you at any time by contacting us at support@keelmoney.com.au.
7.2 We will provide access unless an exemption applies under the Privacy Act.
7.3 If your information is incorrect, incomplete or outdated, you may request that we update or correct it.
8. Retention of Information
We will retain your personal information for as long as necessary to provide services to you, to meet legal and regulatory obligations, and for legitimate business purposes. When no longer required, information will be securely deleted or anonymised.
9. Cookies and Analytics
We may use cookies and analytics tools to collect information about your use of our app and website, to improve functionality and user experience. You can disable cookies in your browser, but some features of our services may not function properly.
10. Complaints
10.1 If you believe we have breached your privacy rights, please contact us at support@keelmoney.com.au.
10.2 We will acknowledge and investigate your complaint within a reasonable period.
10.3 If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
11. Updates to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes via the app or email. Continued use of our services after changes take effect constitutes acceptance of the updated policy.
12. Contact Us
Bundle Services Pty Ltd trading as Keel Money
Email: support@keelmoney.com.au