Privacy Policy

01

Introduction

YB Life Pty Ltd (Faybl), ACN: 667 901 537 is committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act). This policy sets out how Faybl handles personal information.

This privacy policy does not apply to personal information collected by Faybl that is exempted under the Privacy Act, for example employee records.

Our privacy policy will be reviewed regularly to take account of changes in legislation, technology, and our operations and practices. We aim to ensure the policy is appropriate to the changing environment. We will inform you, via our website, of any changes we make to this privacy policy as necessary.

Our privacy policy is based on openness about how we use and protect your information.

Upon your request, we may provide you with a copy of the policy in an alternate format to the website. If you have any enquiries or would like to make a request for a copy of the policy, please contact our Privacy Officer (refer to contact details below).

02

Purposes for which Faybl collects, holds, uses and discloses personal information

We only collect, hold, use, and disclose personal information which is reasonably necessary to ensure that we are able to provide you with the products and services that are appropriate to your needs. We will outline to you when you engage our services the purposes for which we will collect, hold, use, and disclose your personal information.

03

Kinds of personal information Faybl collects

Due to the nature of the products and services we provide, and the requirements of legislation and regulations, we ask for a range of personal information from our customers.

The types of personal information we may collect can include (but are not limited to) details such as:

• Names, employment titles, contact details
• Date of birth and gender
• Information in identification documents (e.g. passport, driver's licence)
• Tax file numbers and other government related identifiers
• Assets and liabilities
• Educational qualifications and employment history
• Personal income
• Visa and work permit status
• Bank account details
• Shareholdings and details of investments
• Superannuation details
• Tax and financial statements
• Information regarding insurance
• Personal information about your spouse and dependants

It may be necessary in some circumstances for Faybl to collect sensitive information about you or your clients to provide specific products and services. The types of sensitive information we may collect include (but are not limited to):

• Health status
• Ethnic origin
• Details of any membership/s to professional associations
• Criminal record

You have a right to refuse to provide us with your personal information or to anonymity or the use of a pseudonym. However, if you do refuse to provide such information, or request the use of anonymity or a pseudonym we may be unable to complete or fulfil the purpose for which such information was collected, including providing you or our clients or your clients with the services we were engaged to perform.

04

Collection, holding, using and disclosing of personal information

When we collect, hold, use, and disclose personal or sensitive information it must be done through lawful and fair means. Consent must be obtained to collect, hold, use and disclose personal information. We are not required to obtain your consent to collect, hold, use of disclose your personal or sensitive information if the collection is required or authorised by or under an Australian law or a court/tribunal order. There are other exceptions to the requirement of obtaining your consent in accordance with the Australian Privacy Principles. If you would like more information on these requirements, please contact our Privacy Officer.

Faybl use a variety of formats for the collection of personal and sensitive information. These include (but are not limited to):

• Requiring clients to complete a Client Profile or other forms
• Information provided by client in an engagement agreement or statement of work
• Receipt of emails, letters and other correspondence
• Telephone calls
• Appointments in person
• Publicly available records
• Electronically stored records
• Through a customer's personal representative
• Through use of our website, such as via contact mailboxes or online enquiry forms, or through the registration process

In every circumstance we will attempt to obtain such personal and sensitive information directly from you. If that is unreasonable or impracticable, we will attempt to obtain such information from other sources in accordance with applicable privacy principles.

You should only provide us with someone else's personal information where you have their express consent to do so and it is for the purpose of us providing services to you. In providing such information you agree that you have obtained the relevant consent and are authorised to do so.

There may be circumstances where we are provided with personal information which we did not actively seek. In such situations, our Privacy Officer will make a determination on whether we could have obtained the information lawfully. If the information was not lawfully obtained it will be destroyed or de-identified.

Security of personal information

Safeguarding the privacy of your information is important to us. We hold personal information in a combination of secure cloud-based computer storage facilities in Australia, but in some cases it may be held offshore in Singapore, United States and other countries, and take steps to protect the personal information we hold from misuse, loss, interference, unauthorised access, modification or disclosure.

Faybl trains its employees and consultants carefully on handling personal information and confidentiality of such information. Once we have no purpose for holding your personal information, we will take all reasonable steps to destroy or de-identify the information.

Disclosure of personal information overseas

Faybl can operate through a network of contractors and alliance firms, both in Australia and overseas, which assist in delivering requested services to clients. To meet the purposes for which your personal information has been collected we may disclose your information to others in the Faybl Group.

Faybl utilises some service providers overseas to process and store data and help deliver services to you. Such overseas disclosure could include but not be limited to service providers located in India, New Zealand, United Kingdom, United States, Ireland, Germany, China, Canada, Indonesia, Singapore, and Hong Kong.

Disclosure to third party service providers

Faybl utilises third party providers (such as IT providers and market researchers) for its business and to deliver services to you. It may be necessary for us to disclose non-sensitive personal information to these providers from time to time. Such disclosure will be in accordance with this Privacy Policy and privacy laws.

Privacy on our websites

The Faybl website may use Google Analytics or other third-party software to analyse user behaviour. These may use cookies, which are text files placed on your computer for the purpose of anonymously identifying your session. These cookies are not used to grant Faybl access to your personally identifiable information. By directing your browser to delete your cookies, this data will be erased.

Any links to third party websites on Faybl's website are not covered by our privacy policy.

Direct marketing

Faybl may engage in direct marketing to you from time to time. When required, your personal information will only be used or disclosed for direct marketing where the information is not sensitive information, is collected directly from you, and there is an easy means to opt out. If you do not wish to receive these materials, please contact our Privacy Officer.

Access to personal information

You have the right to access any personal information regarding you that Faybl holds. Such requests should be made in writing to the Privacy Officer. We will acknowledge your request within 14 days and respond to it within a reasonable time.

Faybl may charge a fee only to cover the cost of locating, retrieving, reviewing and copying any material requested. We will not charge any fee to make the request.

Correction of personal information

Faybl endeavours to ensure that the personal information it holds is accurate and up-to-date. You can make a request to correct the information by contacting our Privacy Officer. If your request to correct is refused you have the option of submitting a statement associated with your personal information.

If you consider that any action of Faybl breaches this policy or the Australian Privacy Principles, you are able to make a complaint. Once we have received your complaint, it will be assessed and acted upon within a reasonable time. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner.

General Data Protection Regulation (European Union)

This section applies if the GDPR (Regulation (EU) 2016/679) applies to our dealings with you, including because we provide services to you and you reside in the European Union.

Where the GDPR applies, we confirm that we will comply with our obligations under the same and you have all of the additional rights set out in the GDPR. We will store your Personal Information for the period we require it to provide services to you, and generally for a period of 7 years after the end of our engagement.

Where you have consented to the processing and use of your Personal Information, you may withdraw such consent at any time. You have a right to require us to erase, restrict, or port your Personal Information as allowed under applicable GDPR articles.

We will transfer your Personal Information outside of the European Union where you have expressly consented in writing or it is necessary for the performance of a contract with you. Note that New Zealand and Canada are recognised by the European Union as offering adequate data protection, but currently Australia is not.

05

Use of Third-Party APIs and User Data

Our application may integrate with third-party APIs to provide features and services that users have explicitly requested. We do not use any data obtained through these integrations to develop, improve, or train generalised artificial intelligence (AI) or machine learning (ML) models.

All user data obtained via these APIs is used strictly for the purpose of delivering our core services and functionality, and is handled in accordance with applicable privacy laws and platform-specific policies (such as Google API Services User Data Policy, including the Limited Use requirements where applicable).