Privacy Policy
Version – 6 November 2024
1. About Us
Kit (“We”, “Us” and “Our”) means CBA New Digital Businesses Pty Ltd (NDB) trading as Hey Kit and a wholly owned subsidiary of the Commonwealth Bank Group which includes the Commonwealth Bank of Australia (CBA) and its subsidiaries (the Group). CBA NDB is responsible for the distribution of the Card and Account and customer service support for Cardholders. Kit is distributed via the Kit app and provides a service for parents or guardians and their children to help raise the financial capability of the next generation by providing simple tools, tips and supporting ideas that promote financial saving, financial independence, and achieving financial goals. Hay the product issuer is responsible for the settlement of transactions using the Card. You can find information about Kit on the Kit website at www.heykit.com.au.
2. Your privacy is important to Us
At Kit, We understand how important it is to keep any personal information We have, including about visitors browsing the Kit website (www.heykit.com.au) (“Website”) or the Kit app (“App”) and registered members of the Website or the App (“You” and “Your”) private, protected and safe. We are committed to protecting the personal information of individuals with whom We deal.
You can be confident that We comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles for the protection and use of personal information. This Kit Privacy Policy (Policy) outlines how We can collect, use, hold and disclose Your personal information.
Please read through this Policy carefully prior to using the Website or the App. The personal information We seek to collect about You is necessary for the service We provide. If You do not provide Us with all of the information We require, We may not be able to deliver Our service to You.
We update this Policy when things change. You can always find the most up-to-date version through Website or the App.
3. What information do We collect?
When You access the Website or the App We collect Your location information, IP address, mobile device and network information. The recording of such information enables Us to optimise the App for Our users, without identifying them.
If You access the Website or the App, We will only store Your personal information if You input into the Website or the App through an online form, e.g. log in, or email to Us.
Identity and Related Information
If You register for a Kit Account and Kit Card through the App, We will collect personal information directly from You. This will include identification information such as:
- Your full name, address and date of birth;
- Your contact details, such as Your email address and phone number;
- Your identity documents, such as Your driver’s licence or passport;
- Your tax residency status; and
- Details about Your children including their names and age.
Information about your child
We will collect some information from You about Your child. If You register for a Kit Account and Kit Card We will also collect Your child’s name and age from You. We will also collect the following information about Your child from their use of the Kit App and the Kit Card:
- their transactional data including spending history on the Kit Card;
- the names and amounts of Your child’s savings goals;
- Their interactions with the educational content in the Kit App and learning data;
- Feedback on whether they are enjoying the Kit App
Information about third parties and service providers
We work with organisations who provide services on Our behalf, such as Hay Limited ABN 34 629 037 403 (“Hay”) who are the issuer of the Kit Account and Kit Card and other third parties who assist with providing access to the Website and the App and delivering Our services. We may collect and share Identity and Related Information with those organisations for those purposes.
We may also collect information from third parties if you choose to link external services to Your Kit account. For example, if you link a Commonwealth Bank of Australia (CBA) account to Your Kit account, We will collect Your CBA bank account details.
Sensitive information
It is unlikely that We will collect information about Your health or ethnicity, from You but if We need to as part of providing You with Our products and services, We’ll ask Your permission and only use it for that purpose.
Our service provider, Jumio, will collect an image of your face and images of your identification documents (such as driving license or passport), for biometric identification purposes on our behalf so we can verify your identity when you open an account.
4. How do We use Your information?
- Establish and verify Your identity;
- Service Your account with Us including linking external services to Your Kit account;
- Improve the products and services on the Website and the App;
- Manage customer offers provided by CBA in relation to Our products and services;
- Manage Our risks and help identify and investigate any illegal activity, such as fraud;
- Contact You, for example if We need to tell You something important or tell You about products or services We think may be of interest to You;
- Handle Your inquiries and communicate with You on Your inquiries;
- Provide any other relevant customer support;
- Conduct internal system development testing and analysis;
- Conduct research and analytical activities; heykit.com.au
- Comply with Our legal and regulatory obligations and assist government and law enforcement agencies or regulators;
- Support Our administrative purposes and any other purposes permitted by law; and
- Any other reason which We specifically notify You of and seek Your consent to prior to using Your personal information.
Spend, savings and learning data we collect about your child is used to provide de-identified, aggregated data insights about how the Kit App is used, that allows us to improve our product and services.
We may send Your information to recipients located overseas, including to service providers and other third parties who operate or hold data outside Australia. The purposes for which We may send Your data overseas include for identity verification purposes, managing customer service, reporting and analytical purposes, and system development testing purposes.
Improvements in technology enable organisations, like Us, to collect and use information to get a more integrated view of users and provide better products and services. We may combine user information with information available from a wide variety of external sources (for example census or Australian Bureau of Statistics data) to analyse the data in order to gain useful insights.
We may use personal information We collect about You to provide direct email marketing offers for Kit products and services, which We think, may be of interest to You, unless You tell Us not to by opting out at any time. Optout may be in the form of an email or other electronic means
5. Cookies and analytics
Cookies are text files that are downloaded to Your computer or mobile device when You access a website. As You browse, cookies gather and store some information about the way You use that website.
Cookies are used on the Website to track Your journey through the Website. The type of cookie We use collects no personal information at all. This simply allows Us to see at a glance which pages and information are of most interest to visitors and members. Most browsers can be configured to refuse to accept cookies. You can also delete cookies, however, doing so may hinder Your access to valuable areas of information within the Website.
We use Google Analytics features based on Display Advertising. You can opt-out of Google Analytics Advertising Feature by using the Google Ad Settings within the web-browser (https://adssettings.google.com/). In addition, you can use the Google Analytics Opt-Out Browser Add-on (https://tools.google.com/dlpage/gaoptout/) to disable tracking by Google Analytics.
We use Branch to track when the Kit app is installed from our paid media and other marketing activities. Branch uses various matching mechanisms to detect Your device, operating system and browser and combine that with cookies to check whether You have the app installed, where You are in the customer on boarding process and which channel You downloaded the Kit app from.
We will share your device ID with Ryvalmedia, The Trade Desk and SCA Listnr for the purposes of analytics and user profiling to allow us to gather insights and refine our advertising. Foxcatcher will develop those insights based on encrypted data and will not have access to the device ID’s. Device IDs are captured from the device You use to open Your Kit Account.
6. Who do We share Your information with?
- Our parent company, the Commonwealth Bank of Australia ABN 48 123 123 124 (CBA);
- Our third-party product issuer of the Kit Account and Kit Card;
- Online identity verification and authentication providers;
- Our suppliers, agents, associates, contractors and external service providers (including, for example, our product issuer, card manufacturer, information technology and marketing technology);
- Our financial advisers, legal advisers or auditors;
- Regulatory bodies, government agencies and law enforcement bodies in any jurisdiction; and
- External dispute resolution schemes
7. Keeping Your information safe
8. Accessing, updating and correcting Your information
9. Other important information
We provide You with links from Our Website to other third-party sites. The provision of a link does not imply any endorsement, nor can We accept responsibility for the conduct of third parties linked to Our Website. Once You transfer from Our Website to another website, We are not responsible for the conduct or practices of those third-party websites. When You transfer to another website and before disclosing Your personal information on that website, You should check the applicable privacy policy of that website.
Sometimes We update Our Privacy Policy. Any modifications will be effective immediately upon posting the amended Privacy Policy on the Website or the App. We may contact You or notify You when You log into the Website or the App that there have been changes to Our Privacy Policy. You can always find the most up-todate version on the Website at www.heykit.com.au/privacy-policy
10. Making a privacy complaint
Email: info@afca.org.au
Phone: 1800 931 678 (free call)
Postal Address: Australian Financial Complaints Authority, GPO Box 3, Melbourne, VIC, 3001
Office of the Australian Information Commissioner (OAIC)
Ph: 1300 363 992
Postal address: Office of the Australian Information Commissioner, GPO Box 5218, Sydney, NSW, 2001
11. Contact Us
- Have a concern about the handling, use or disclosure of Your personal information;
- Would like further information about the way We manage the personal information that We hold;
- Wish to access or update Your personal information; or
- Have any other query or concern
Our registered business address is: CBA New Digital Businesses Pty Ltd trading as HeyKit
Commonwealth Bank Place South
Level 1
11 Harbour Street
Sydney NSW 2000