Privacy Policy

At the.Body, we value your privacy and are committed to protecting your personal information. This Privacy Policy explains how we collect, use, and disclose your information when you use our website. The Body AU trading as the.Body (ABN 90 629 920 943). When we collect, store and use your personal information, we do so in accordance with the rules set down in the Australian Privacy Act 1988 (Cth) and by the European Union General Data Protection Regulation (EU) 2016/279 (the GDPR).

Information We Collect

When you visit our website, we may collect certain information about your device, including your IP address, browser type, and operating system. We may also collect information about your browsing behavior, such as the pages you visit and the time spent on each page.

How We Use Your Information

We use the information we collect to improve our website and provide you with a better browsing experience. This includes analyzing trends, personalizing content, and optimizing our website's performance.

Disclosure of Your Information

We may disclose your personal information to third parties in certain circumstances. For example, we may share your information with service providers who help us operate our website or fulfill your orders. We may also disclose your information if required by law or to protect our rights or the rights of others.

Security Measures

We take the security of your personal information seriously and have implemented measures to protect it from unauthorized access, use, or disclosure. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Third-Party Links

Our website may contain links to third-party websites. These websites have their own privacy policies, and we are not responsible for their practices. We encourage you to review the privacy policies of any third-party websites you visit.

Children's Privacy

Our website is not intended for children under the age of 18. We do not knowingly collect personal information from children under the age of 18. If you believe we have collected personal information from a child under the age of 18, please contact us immediately.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Any changes will be posted on this page, and the revised policy will take effect immediately upon posting.

Contact Us

If you have any questions or concerns about our Privacy Policy, please contact us at the following email address:

The Body AU(ABN 90 629 920 943)

Email: info@the-body.com.au

Last update: 24 April 2024

This Privacy Policy describes how Afterpay and affiliates (“Afterpay,” “we,” “us”, and "our") collect, use, disclose, transfer, store, retain or otherwise process your personal information ("your", “you”, and "Merchant") when you visit our website, apply for and use our Merchant product and related services, or otherwise interact and engage with us in relation to our Merchant products, features, and services, including as outlined in our Terms of Service ("agreement") (collectively, "Services"). The Afterpay entity you are interacting with will be based on your country of residence. A list of Afterpay entities can be found in 11. How to Contact Us below. 

Partners, merchants, online market places, and suppliers that Afterpay interacts with are independent of Afterpay and responsible for their own privacy policies and practices. This includes, content on their websites or app, and products or services provided. Please refer to their Privacy Policy or reach out directly to these third parties for further information. 

Our Privacy Policy explains:

1. Personal information we collect about you and why 

2. When and with whom we share your personal information

3. How we secure your personal information

4. How we use cookies and similar technologies

5. How long we keep your personal information

6. Your rights and choices

7. Rights of California residents

8. International Data Transfers

9. Children's Personal Information

10. Changes to this privacy policy

11. How to contact us

1. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND WHY

 Personal information reasonably identifies you and is about you, directly or indirectly, as described in applicable privacy laws in places we operate in. 

 We collect and process personal information about you in three ways: 

(i) when you provide it to us directly; 

(ii) when we gather personal information while you are using any of our Services, including through cookies and similar technologies (see 4. How We Use Cookies and Similar Technologies below); and 

(iii) when we collect personal information from other third party sources.  

We explain in the table below what types of personal information we collect and process, how and why we do so, and the lawful bases that apply in particular as prescribed under the General Data Protection Regulation and UK General Data Protection Regulation. We will collect and process your personal information with your knowledge and consent, including as set out in this Policy, except where otherwise required or permitted by law. We may collect or process personal information in other ways than as described below. We will let you know at that time, unless otherwise inappropriate or unlawful to do so.  

If you fail or refuse to provide us with personal information we request from you directly, or we do not obtain your consent where we rely upon it, including to gather personal information while you are using our Services or from third party sources, we may not be able to proceed with entering into or fulfilling some of our Services. Consequently, we will not be able to provide or continue to provide those Services to you. This includes, but without limitation, setting up your Afterpay account, or responding to a support request or complaint.

Purpose of processingCategories of personal information we collect and howWhy we collect and process personal information, and lawful bases where applicable

To reach out and understand whether you may be interested in applying to be a Merchant with us, including when you have completed our online business sign up and inquiry pages, or when we have received your personal information from other sources.

From you -

• Contact information, such as your name, address (and location), phone number, and email

From other sources -

• Contact information, such as your name, address (and location), phone number, and email. We collect these from third parties (such as a Merchant who has referred you under our Merchant Referral Program), publicly available sources (eg. your website or Linkedin), and other third party sources

• With your consent
• Our legitimate interests to promote our products and services, and yours, where otherwise permitted and consistent with applicable law, so that we can explore opportunities and benefits of the use of our Services

To create (and assess whether to create) an Afterpay account, including to carry out our identity and account verification process and to enable you to authenticate into your account once created.

From you -

• Contact information, such as your name, address (and location), phone number, and email
• Financial and business-related information, such as bank account details
• Identity information, such as your date of birth, driver’s license, passport, and other requested identification information documents

From other sources -

• Confirmation of your identity through verification processes from identity verification and fraud prevention providers, and credit reference agencies, who may validate the information you provide us with other information from publicly or commercially available sources. Your personal information may also be screened against relevant sanctions watchlists.
• We may search online for any publicly available information about you, such as adverse media, through our onboarding process, and ongoing review of your suitability to provide our Services.
• Legal obligation - to comply with applicable anti-money laundering and counter terrorism financing and sanctions laws
• To take steps to enter into and for the performance of our agreement with you
• For our legitimate interests to protect our business, and to confirm your identity, to detect, prevent and investigate suspected or actual money laundering, fraud, or other crimes or illegal activities

To provide our Afterpay account Services, including setting up your business’s Service account to interact with you and deliver our Services, such as sending you communications as necessary about our Services, invoices, and agreement updates

From you -

• Contact information, such as your name, address, phone number, and email.
• Communications between us
• For the performance of our agreement with you

To send you direct marketing and other promotional communications, before or after you apply to become a Merchant, including to offer new partnerships and promotion opportunities. 

Where permitted, we may opt you in to marketing communications, but you can opt out at any time by clicking the unsubscribe link at the bottom of these messages. Refer also to 6. Your Rights and Choices below.

From you -

• Your contact details, such as your email address
• With your consent, or for our legitimate interests to promote our products and services, where otherwise permitted and consistent with applicable law

To provide you support, including to resolve disputes, collect fees, and troubleshoot problems

From you -

• Identity verification information requested from you to discuss your account with you
• Information about the subject of your support request or complaint

From other sources -

• Identity verification information requested from an agent you have authorized to discuss your account on your behalf
• Information relevant to the subject of the support request or complaint from merchants or other relevant sources
• For the performance of our agreement with you
• For our legitimate interests, such as to investigate or respond to a support request or complaint

To detect, investigate and prevent suspected or actual fraud, money laundering, or other crimes or illegal activities on an ongoing basis , including credit card rules, and to protect Afterpay’s legal rights and claims

From your use of our Services -

• Information about your use of our Services

From other sources -

• Information from third parties about you as consistent with applicable law, including from our affiliates
• For our legitimate interests, in establishing any risks in providing services to you and to prevent, detect and prosecute fraud and other crimes

To learn more about your level of satisfaction, your expectations of us and our Partners, and how we can meet them, so that we can customise, measure, and improve our Services including its content, layout and operations.

We may send you survey requests to do so.

We may use this information to produce statistics and reports about our Services and operations. We will typically use this information to create aggregated or anonymised information and only use personal information where necessary.

From you -

• Feedback you provide us about our Services and interactions with us and our partners

From your use of our Services -

• Information from you, your use of our Services, and other sources, as detailed in this section of our Privacy Policy.

• Our legitimate interests to understand our Merchants so that we can provide a better experience for you and everyone, and to maintain and improve our Services

To make our app or site work as you’d expect it to, such as to prevent and respond to suspected or actual malicious software or activity, for secure identity verification and login, fraud prevention, and remembering your cookies choices.

This includes personal information collected and processed by the use of cookies and similar technologies. Refer to 4. How We Use Cookies and Similar Technologies below

From your use of our Services

• Technical information, such as date and time you visited a site or took an action, IP address, login details, your location, device or browser settings
• Cookies consent preference
• To enter into and for the performance of our agreement with you
• Our legitimate interests, to provide a secure and functioning delivery of our Services

To provide by the use of cookies and similar technologies on our website and app better functionality, to assess our performance, for advertising by us and our digital partners, and to provide a personalized experience. Refer also to 4. How We Use Cookies and Similar Technologies below

From your use of our Services -

• Technical information, such as date and time you visited a site or took an action, IP address, contact details such as your email address, your geolocation, device or browser settings
• With your consent or where otherwise consistent with applicable law

For other purposes you have specifically consented to

From you, from the use of our Services, or other sources. For instance, if we collect and process personal information categorized as “sensitive” or “special” under applicable laws, such as your health information, to deliver our Services, we will only collect this information where it is reasonably necessary and we have your consent, or where required by and consistent with applicable laws.Other information from you, from the use of our Services, or other sources as explained to you at the time we seek your consent.

• With your consent

As required or permitted by applicable laws and regulations , including to satisfy our bookkeeping, taxation, auditing, and accounting requirements, and to carry out business, operational, and legal functions.

Unspecified information from you, from the use of our Services, or other sources.

• As required or permitted by applicable laws and regulations

2. WHEN AND WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

We may share personal information described in 1. Personal information we collect and why section with the following categories of service providers and other third parties.

Categories of third partiesWhen and why we may share your personal information

Affiliates within our group of companies

Such as, Cash App, Square, or other wholly-owned subsidiaries of Block Inc.

We may share your personal information for the following purposes for our legitimate interests or as otherwise required or consistent with applicable law.

• To provide (or assess to provide), maintain or improve our Services
• To understand how you engage with our Services to help make them better for you and for everyone
• To help us manage our relationship with you across our group of companies and for customer support issues and to enforce our agreement with you, including in cases of debt recovery;
• For us and our affiliates to prevent, detect, and prosecute money laundering, fraud and other crimes or illegal activities
• For marketing purposes where legally permitted
• As instructed by you and choices available to you
• As required or permitted with applicable law

Service Providers and sub-contractors

We share your personal information with the following Service Providers based on our legitimate interests to provide, maintain and improve our Services.

• Technology and IT infrastructure providers to store information and to provide software or programs that help us provide our Services
• Marketing or event providers that help us run our advertising campaigns, contests, special offers, or other events or activities
• Identity verification and fraud prevention providers and credit reference agencies to help us confirm your identity and prevent fraud, to assist us in meeting our obligations under anti-money laundering / counter terrorism financing and sanctions laws, and other compliance requirements. These companies process your personal information in accordance with their own privacy policies
• Financial partners, like financial institutions, payment networks, payment card associations, and credit bureaus that help us provide our joint Services;
• Outbound phone and text messaging services. Our Service Provider may need to access and intercept messages between us and your from time to time or disclose your personal information to a government body or telecommunications network provider to comply with applicable telecommunications laws, or a court or tribunal order
• Customer service agencies, to support manage our relationship with you
• Analytics providers, to understand how you engage with our Services to help make them better for you and for everyone. For example, we partner with third-party analytics providers, like Google, to help us understand how you use our services so that we can improve our customer experience

Your customers

We share your personal information with customers that you engage and transact with using our Services for the following purposes to fulfill our agreement with you

• To assist you to manage an order, including dealing with any refunds, disputes, or claims, or in regards to an inquiry or complaint made by a customer

Online trackers

We may share your personal information for the following purposes with your consent, for our legitimate interests, or as otherwise consistent with applicable law

• Consistent with applicable law and choices that may be available to you, we share your personal information with partners that help analyze our site and track metrics on our behalf or in connection with our Services. Refer to 4. How We Use Cookies and Similar Technologies for more information

Companies that we plan to merge with or be acquired by or who may invest in us

We share your personal information for the following purposes for our legitimate interests.

• For business transfers and corporate changes to enable the assessment or completion of the relevant merger, restructuring, financing, acquisition, divestiture, dissolution or other corporate change. If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all of our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change
• To ensure that we or our business remains commercially viable
• To a subsequent owner, co-owner, or operator of one or more of the Services to enable them to continue to run the Services after the change of owner or operator

Law enforcement agencies, government agencies, officials, or other authorities or third parties pursuant to a subpoena, court order, or other legal process, requirement, or legitimate interest

We share personal information for the following purposes for our legitimate interests, to protect our business and enforce our agreement with you, or where required or authorized by law.

• To detect, investigate and prevent suspected or actual fraud, money laundering, or other crimes or illegal activities, including credit card rules
• To comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.)
• To establish, exercise or defend our legal rights, including to enforce our agreement with you
• To protect ours or our customers' rights or property, including from harm, fraud, or potentially prohibited or illegal activities, and for the security or integrity of our Services

With your consent

• Other third parties with your consent or direction to do so, such as to provide (or assess to provide) our Services

Other third parties where required by law, or our legitimate interests as permitted by law

• To comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.)
• Other purposes as permitted by applicable laws

3. HOW WE SECURE YOUR PERSONAL INFORMATION

We take appropriate measures, including administrative, technical, and physical safeguards, to protect your personal information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. The internet is not a 100% secure environment, so we cannot guarantee absolute security of the transmission or storage of your information. We are an ISO 27001 compliant company, and require our third parties to meet appropriate privacy and security standards when handling data on our behalf. Your personal information will be accessible by our employees, contractors and service providers who require access for the purposes described in this Privacy Policy.

For more information about our security practices, please visit https://www.afterpay.com/en-AU/security or refer to 10. How to Contact Us below.

4. HOW WE USE COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small data files stored on your browser or device. They may be sent by the operator of the site or app you are visiting, in this case Afterpay (“first-party cookies”), or by third parties, such as our service providers and digital partners (“third-party cookies”). Other similar technologies may be used, such as tracking pixels or browser local storage (together “cookies”). For example, we partner with third-party analytics providers, like Google, to help us understand how you use our services so that we can improve your experience with us. The analytics providers that administer these services use cookies to help us analyze how you use our online services. We may disclose your site-use information (including IP address) to these analytics providers, and other service providers who use the information to help us figure out how you and others use our online services. To learn more about Google Analytics and how to opt out, please visit https://marketingplatform.google.com/about/ or https://support.google.com/analytics/answer/181881?hl=e.

When you visit our website or app, we use cookies as necessary to make our Services work, to improve our performance and functionality, or to personalize your online experience.

You may see certain interest-based advertising on other websites or online services based on information relating to your access to and use of our Services and other websites. This is because we work with interest based advertisers to promote our Services consistent with applicable law. Third party services use personal information we provide to deliver Afterpay advertisements on third party websites that may be tailored to your individual interests. These interest based advertisers may also use personal information about you that they have independently collected and in accordance with their privacy policy and practices, including through the use of cookies. 

Your browser or device may offer settings to control cookies. Selecting “Limit Ad Tracking” (for iOS devices), or “Opt out of Interest-Based Ads” (for Android devices), will allow you to limit our use of information collected from or about your mobile device (such as precise location data) for the purposes of serving interest-based advertising to you. You may also opt-out of receiving ads from us or our partners by using our partners’ settings or by heading to Your Online Choices (EU/UK) or Your Ad Choices (other countries) for more information. As a heads up, blocking or opting-out of some types of cookies may impact your experience and the Services we are able to offer.

Certain web browsers allow you to instruct your browser to respond to Do Not Track ("DNT") signals to websites you visit, informing those sites that you do not want your online activities to be tracked. At this time, our websites are not designed to respond to DNT signals or similar mechanisms from browsers.

If you are based in the EU or UK, head to "Cookies" on our website for further information and to manage cookies on our website or app.

5. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

The retention periods for personal information we collect and process about you are determined on a case-by-case basis that depends on the following factors below.

 The nature of the personal information, and why it is collected and processed, as described in this Privacy Policy. This includes to provide our Services, to comply with legal obligations, to enforce and prevent violations of our agreement with you, and to protect us against fraudulent activity.

To manage and enforce our agreement with you. Your use of our Services is subject to the agreement between us. So if, for example, you close your Afterpay account, we retain personal information about you for a period of time so as to collect any debt or fees owed, resolve disputes, troubleshoot problems, assist with any investigations or complaints, and to prevent fraud or risk.

To establish, exercise, or defend our legal claims or rights. For example, we preserve your personal information related to a legal claim or complaint, such as where we are subject to a regulatory investigation, or we need to defend ourselves in legal proceedings involving your personal information, or respond to a government authority or body in relation to a legal or regulatory complaint made by you or someone else.

As required or otherwise permitted by applicable law. For example, retention periods may be imposed under law or regulation for a prescribed period of time. For instance, to protect our or other’s legitimate interests, such as to prevent fraud.

Once the retention periods applicable to your personal information expires, we will otherwise take steps to delete or anonymize personal data where we no longer have a lawful basis to retain your personal information. 

6. YOUR RIGHTS AND CHOICES

You can see or change personal information you gave us, ask us to close your account, control your device location tracking settings, or tell us to stop direct marketing to you at any time. Head to our Help Centre at any time by clicking "Help" on our website or app for detailed instructions. We also respect other privacy rights and choices you make consistent with applicable law. These rights and choices available to you are based on your country of residence and which Afterpay entity you are dealing with, and are subject to limitations as required or permitted by applicable law. 

We may ask you to verify your identity in accordance with our standard procedures, including any authorized agent who would like to act on your behalf, or clarify your request, before taking further action on your privacy right or choice request. We endeavor to respond and address all privacy rights and choices requests within the applicable statutory time frame. We will let you know if we need more time, and why. We may not always be able to fulfill your request if we have a legitimate basis to refuse it. We will tell you why. For example, if you seek to erase your personal data in a way that would mean we are not able to comply with our obligations under law. 

If you would like to make a privacy right or choice request, please refer to 11. How To Contact Us below.

Rights and choices that may be available to you, based on your country of residence

Right toDescription

Withdraw your consent

You have the right to withdraw your consent where we have relied on it to process your personal information. If you withdraw your consent, we may not be able to provide you with certain Services. It will not affect our lawful basis for processing based on consent before your withdrawal.

Access

You have the right to request a copy of your personal information held by us.

Further information

You have the right to enquire further about the personal information we hold about you and our privacy practices, including how we transfer personal information internationally and onward disclosures of personal information

Correction

You have the right to ask us to correct your personal information held by us, including where you believe it is not accurate, complete, up to date, or relevant.

Erasure

You have the right to ask us to erase your personal information, and where personal information is made public, to inform other controllers of your personal information to erase your personal information where you have a lawful erasure right.

Restrict Processing

You have the right to ask us to restrict processing of your personal information.

Object to processing

You have the right to object to us processing your personal information where we process it based on our legitimate interests, including for direct marketing purposes and other profiling activities. You can also opt out of direct marketing at any time as described above.

Data Portability

You have the right to ask us to access or transfer on your behalf personal information we hold about you to a third party in a structured, commonly used and machine-readable format.

Make an enquiry or complaint

You have the right to make an enquiry or complaint, including to lodge a complaint with your local privacy authority.

Object to automated decision making

You have the right to object to solely automated decisions that we may have made about you that produce a legal or similarly significant effect, and ask for more information about the decision and have a person review it, unless we are prohibited or exempt from doing so under law.

More information

We use systems to make decisions about you through automated means, including behavioral profiling, without our staff being involved. We complete the following decision making by automated means, with legal or similarly significant effects on you, to enter into and perform our Services you request from us, or to comply with laws that apply to us:

• Verify your identity to assess your application to provide you our Services. This decision helps us make sure we’re lending responsibly, and helps us prevent fraud, money laundering, terrorism financing, and allows us to check against sanction lists in relevant cases.

These decisions rely on personal information we collect or hold about you from your applications and your interactions and experiences with us, such as transactions attempted to be made or made to your company. We may also use information about you we collect from third party credit reference and fraud prevention agencies.

Automated decisions can affect the products, services or features we may offer you. As a result of the above decisions, you may be declined access or have limited access to our Services. We perform regular checks of our automated decision models to ensure they are operating correctly.

7. RIGHTS OF CALIFORNIA RESIDENTS

If you live in California, the following additional rights apply to you.

Right toDescription

Know

You may have the right to request, up to twice in a 12-month period, to see the following information about the personal information we have collected about you:

• The categories and specific pieces of personal information we have collected about you;
• The categories of sources from which we collected the personal information;
• The business or commercial purpose for which we collected the personal information;
• The categories of third parties with whom we shared the personal information; and
• The categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.

California law also gives you the right to ask if we share your personal information to third parties for their direct marketing purposes (we do not disclose your personal information for unaffiliated third parties’ direct marketing purposes).

Erasure

You have the right to ask us to delete the personal information we have collected from you (subject to exceptions the law provides). Please note that you may no longer be able to use our Services if you delete your personal information.

Correction

You have the right to correct the personal information we have collected about you (subject to exceptions the law provides).

Non-Discrimination

You have the right to not be discriminated against if you exercise these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise these rights.

Opt-Out

You have the right to opt-out of the sharing of your personal information for purposes of certain targeted advertising known as cross-context behavioral advertising. If we share your personal information to third parties for such purposes, we will provide you the right to opt out of such sharing (subject to exceptions the law provides). Although some of the information we collect and process about you may be considered sensitive personal information, we only process such information for purposes authorized by law, such as to provide services you request from us or to verify your information.Although we disclose your personal information to third parties as described above, we do not sell your personal information.

How to Exercise Your Rights

You may submit an access, deletion, or correction request here or by emailing privacy@afterpay.com. To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request. You may also designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Exceptions to These Rights

California law provides for certain exceptions to the rights described above. We reserve the right to avail ourselves of these exceptions where applicable. For example, these rights do not apply to personal information collected, processed, shared, or disclosed pursuant to the Gramm-Leach-Bliley Act.

8. INTERNATIONAL DATA TRANSFERS

Personal information we collect and handle about you may be transferred to or stored in a jurisdiction outside your country of residence and where the Afterpay entity you are dealing with operates. We may do so, for example without limitation, when sharing personal information with our affiliates and service providers to help us provide (or assess to provide) our Services or other third parties that we partner with. Your personal information may be transferred to or stored in Australia, New Zealand, the United States, Canada, United Kingdom, the European Union, China, and Singapore. We may transfer your personal information to other countries, but we will always take steps to ensure your personal information is afforded equivalent levels of protection and rights as are required under your country of residence and where the Afterpay entity you are dealing with operates. For more information please reach out using the details in 10 How to Contact Us below. 

We take steps to ensure your personal information is afforded equivalent levels of protection and rights as are required under your country of residence and where the Afterpay entity you are dealing with operates. 

Where we transfer your personal information outside the United Kingdom or European Union to countries that are not covered by an adequacy decision of the UK government or European Commission (as applicable), we use appropriate safeguards that include Standard Contractual Clauses approved by the UK's Information Commissioner's Office or European Commission as appropriate, or other applicable measures, including transfers to a third party that has implemented Binding Corporate Rules, or specific situations outlined under Article 49 of the UK GDPR / GDPR. You can access a copy of the Standard Contractual Clauses approved by the UK Information Commissioner's Office here, and the Standard Contractual Clauses approved by the European Commission here. Afterpay entities are bound by an Intercompany Personal Data Transfer Agreement that contains Standard Contractual Clauses.

For further information about our policies and practices with respect to international data transfers, please refer to 10. How To Contact Us below.

9. CHILDREN'S PERSONAL INFORMATION

Our Services are not directed at children under the age of 18. If we learn that any personal information we collect has been provided by a child under the age of 18, we will promptly close the relevant account and delete that personal information as consistent with applicable law.

10. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time, as may be required. We will provide you with reasonable prior notice of any material changes in how we use your personal information, including by email if you have provided one. If you disagree with these changes, you may cancel your Afterpay account at any time. Any amendments will be published by posting a revised version of the Privacy Policy and updating the “Effective Date” and "Posted Date" above. The revised version will be effective on the “Effective Date” listed.

11. HOW TO CONTACT US

If you have any questions or concerns regarding this Privacy Policy, or would like to exercise your rights and choices, you can get in touch with us by contacting your country specific Afterpay entity below. If you are dissatisfied with our response, you have a right to make a complaint to your local privacy authority, with a link to their contact page below.

CountryContact DetailsLocal Authority

Australia

Submit a request here

privacy@afterpay.com

GPO Box 2269, Melbourne, VIC 3001, Australia

Office of the Australian Information CommissionerCanada

Submit a request here

privacy@afterpay.com

760 Market St., 2nd Floor, San Francisco, California, United States of America 94102

If you would like to speak to the Afterpay Privacy Lead, please address your communication accordingly.

Office of the Privacy Commissioner of Canada

European Union

Submit a request here

privacy@clearpay.com

Paseo de la Castellana, 95, 28046 Madrid, Madrid, España

If you would like to speak to the EU Data Protection Officer, please address your communication for the attention of the Data Protection Officer.

Clearpay S.A.U Limited is the Data Controller for the purposes of the General Data Protection Regulation (GDPR).

Agencia Española de Protección de Datos

New Zealand

Submit a request here

privacy@afterpay.com

TMF Group, Level 11, 41 Shortland Street, Auckland 1010

New Zealand Privacy Commissioner

United Kingdom

Submit a request here

privacy@clearpay.co.uk

101 New Cavendish Street, London, W1W 6XH

If you would like to speak to the UK Data Protection Officer, please address your communication for the attention of the Data Protection Officer.

Clearpay Finance Limited is the Data Controller for the purposes of the General Data Protection Regulation (GDPR) and U.K. GDPR / Data Protection Act 2018.

Information Commissioner’s Office

United States

Submit a request here

privacy@afterpay.com

760 Market St. Floor 2 Unit 2.03, San Francisco, CA 94102

Klarna’s Privacy Policy

We at Klarna care about your privacy. Therefore, we always collect and handle your personal information responsibly and with your privacy in mind. This Privacy Policy describes how Klarna Australia Pty Ltd (“Klarna”) collects and uses your personal information when you use any of Klarna’s services (the “Services”) and become a customer of ours. Examples of use of our Services are when you pay with any of our payment methods, when you contact us, when you use the Klarna web portal and mobile application (the “Klarna App”), or when your information is autofilled in the checkout of a store that uses Klarna. This Privacy Policy also describes your rights in relation to our use of your personal information, and how to exercise those rights.

This Privacy Policy applies, except for what is stated in Section 1 below, to all customer personal information that Klarna handles. It is therefore important that you read and understand this Privacy Policy.

Some of our Services will provide you access to content and functionality offered by other companies or organizations other than Klarna (“Third-Party Services”). This is for example the case when we link to third-party sites from our websites, and when you access third-party sites while using the web browser in the Klarna App. This Privacy Notice does not apply to the collection and use of your personal data in Third-Party Services, and Klarna is not responsible for such third parties’ processing of your personal data.

"We", "our" or "us" means Klarna Australia Pty Ltd registered with the Australian companies register under the registration number ABN 82 635 912 579.

1. Other Klarna privacy policies

Separate privacy policies may apply for specific campaigns or offers which are temporarily available. If so, such separate privacy policies are presented in connection with the campaign or offer.

If you are employed by Klarna, a candidate applying for a job at Klarna, or an employee of a store that cooperates with Klarna, we also have separate privacy policies explaining how we handle your personal information. You will be provided the relevant privacy policy in connection to your contact with Klarna, and you may also contact us using the information in Section 15 below if you want a copy of the relevant privacy policy.

2. What information do we use?

2.1 Information you give us 

You may give us information about yourself when you use one of Klarna’s Services, for example when you choose to pay with one of Klarna’s payment methods, contact us, or use the Klarna App. Please note that you are only allowed to provide your own personal information when using the Services, for the Services to be provided correctly.

Depending on which Service you choose to use, this personal information will be:

• Contact and identification information – name, date of birth, national ID number, title, billing and shipping address, email address, mobile phone number, nationality, etc.
• Payment information – credit and debit card information (card number, validity date, and CVV code), bank account number, etc.
• Sensitive information – you may, at your sole discretion, choose to provide us information about you which constitutes “sensitive information” according to Australian legislation, including membership of a professional or trade association or trade union, sexual orientation, health information, etc. We will never require this type of information from you in order to provide you with our Services. Providing us with this information will be strictly voluntary and based on your explicit consent. Please see Section 5 for information about how you can revoke your consent.

You can at any time change your profile information such as your contact information and other editable settings. This can be done either in the Klarna App or by contacting us.

2.2 Information we collect about you 

Depending on which Services you choose to use, we may collect the following information about you, either ourselves or via third parties (for example credit reporting bodies, stores or public databases):

• Contact and identification information – name, date of birth, government identification numbers (such as your drivers licence or passport number), title, billing and shipping address, email address, mobile phone number, nationality, etc.
• Information on goods or services – details about the goods or services you purchase or order, including for example type of goods or shipment tracking number.
• Credit information – details relating to your credit history, credit worthiness or capacity, and credit eligibility information, which we may collect from you, other credit providers, or credit reporting bodies.
• Information about the interaction between you and Klarna – how you use the Services, including information on outstanding and historical debts and your repayment history with Klarna; technical data such as page response times, download errors, personal preferences; your interactions with the Klarna customer service, etc.
• Recorded telephone conversations – we record telephone conversations if you call our customer service.
• Information about the interaction between you and stores – your dealings with stores you visit or shop with, such as information about whether you have received the goods, and type of store.
• Device information – e.g. IP address, language settings, browser settings, time zone settings, operating system and platform and screen resolution. To learn more about how we may collect information from your device, or store information on your device, please see Section 13 below.
• Information from external sanction lists and PEP lists – we may screen your information against lists of persons subject to sanctions, and lists of persons who are so called Politically Exposed Persons. These lists include information such as name, date of birth, place of birth, occupation or position and reason for being listed.
• Social media profile – if you have clicked on one of our promotions or event notices posted on a third-party social media website we may receive contact information provided as part of your user profile of such social media (such as your name, e-mail address and telephone number and any other relevant business information such as your organisation’s name, address and your industry).
• Service-specific information – in order to provide you with some of our Services (e.g., Klarna app, our browser extension, etc.) we may collect and handle additional personal information that is not covered by the above categories. Please see Section 4 below in order to find out which additional personal information is processed for the respective Service.
• The Klarna app and our browser extension use information. All content you upload (such as images or receipts), location information, information about how you use the browser in the app, and the websites you visit when you have our browser extension installed.

3. What personal information do we process and for what purpose?

Depending on which Services you use, Klarna may handle your personal information for the purposes listed below. We collect and use your personal information to provide you Services, understand how Klarna’s Services are used, and to improve the Services that we offer to our customers. These purposes are further described in the below table. You can find more specific information about how we process your information in some of our Services in Section 4 below.

Processing in order to provide the Services

Purpose of the processing

Personal information 

Administer the customer relationship with you in different ways, for example to process your payment or carry out our obligations arising from credit contracts entered into between you and us.

All of the personal information categories under Section 2.

Create and send information to you in electronic format (non-marketing).

All of the personal information categories under Section 2.

Assess which is the most suitable way to contact you to inform you about outstanding debts.

Contact and identification information, credit information (if we have this available) and information about the interaction between you and Klarna.

Conduct customer satisfaction surveys and consumer research regarding our Services (for example after you have contacted Klarna’s customer service) via email, sms, phone, or through other means.

You can object to this at any time. You will also be informed about your right to opt-out from these communications every time your email or phone number is used for this purpose.

Contact and identification information, information on goods or services, information about the interaction between you and Klarna, and information about the interaction between you and stores.

Carry out credit assessment before granting credit (Please see Section 4.1 on Klarna’s credit Services and Section 8 regarding how we cooperate with credit reporting bodies). Managing our credit relationship with you including for administration and collection purposes.

Contact and identification information, credit information and information about the interaction between you and Klarna.

Prevent IT attacks (for example DDoS attacks) toward Klarna’s Services, as part of our efforts to keep our Services safe and secure.

Contact and identification information, information about the interaction between you and Klarna, information about the interaction between you and stores, as well as device information.

To be able to treat you as a vulnerable customer (if you due to personal circumstances are in a vulnerable position).

Contact and identification information, and other personal information, including sensitive information.

Improve our Services, training and quality assurance, as well as documenting what has been discussed and decided between you and Klarna’s customer service.

Recorded telephone conversations.

Transfer your information to stores, suppliers and/or other recipients such as the Klarna group. (Please see Section 6 for more information on how we share your information and why).

All of the personal information categories under Section 2.

Carry out risk analysis, fraud prevention and risk management (for example through verifying your identity, and carry out checks with fraud prevention companies, etc).

All of the personal information categories under Section 2.

Perform debt collection services, i.e. to collect and sell debt.

Contact and identification information, information on goods or services, credit information, information about the interaction between you and Klarna and information about the interaction between you and the stores.

Product improvement and research

Anonymise your personal information for product development in order to analyse customer behaviour.

All of the personal information categories under Section 2.

Perform data analysis for product improvement and product testing (for example to improve risk- and fraud models).

All of the personal information categories under Section 2.

Enable internal research and creation of statistical models.

All of the personal information categories under Section 2.

Enable external research, for example by universities or other bodies. 

All of the personal information categories under Section 2.

Compliance and to protect Klarna from legal claims

Comply with applicable laws, such as anti-money laundering and bookkeeping laws.

All of the personal information categories under Section 2.

Perform screening against lists of persons subject to sanctions, and lists of persons who are so called Politically Exposed Persons.

Contact and identification information, information from external sanction lists and PEP lists.

Protect Klarna from legal claims, and enforce Klarna’s legal rights.

All of the personal information categories under Section 2.

To provide marketing

To provide marketing communications about our Services, offers and promotions, to you, other customers and prospective customers, as well as marketing communications regarding the products and services of merchants and partners at which Klarna’s Services can be used.

For the purpose of providing targeted marketing to you, other customers and prospective customers, we may also share your information with third-party analytics services. These third party analytics services may share your data with advertising services that market to you, other customers and prospective customers.

You may always opt out by contacting us, see Section 15. Our marketing emails also contain an unsubscribe facility.

Contact and identification information, information about the interaction between you and Klarna, information about the interaction between you and stores, device information, your IP address and event data on the Klarna App.

To decide which marketing to provide you. This processing also ceases when you opt out from receiving marketing.

Contact and identification information, information on goods or services, information about the interaction between you and Klarna, information about the interaction between you and stores, device information and service-specific information.

To provide “sponsored links” to products and services of stores.

Information about goods/services, information about the interaction between you and Klarna, information about the interaction between you and stores, device information and service-specific information.

4. Service-specific processing of personal information in some of Klarna’s Services

This Section sets out certain processing of your personal information which is specific for certain Services. To learn more about our Services, and their included features, please consult the terms and conditions of the respective Service.

4.1 Klarna’s Credit Services

The following Services involve us giving you a credit: Pay later (invoice) and Financing, as well as Klarna Card and the One-Time Card (both available in the Klarna App). To provide these Services, we do a credit assessment of you. The credit assessment is based on contact and identification information you have provided, information about the interactions between you and Klarna, and credit information, which includes information obtained from credit reporting bodies, such as your income and repayment history information. You can read more about our use of credit reporting bodies in Section 8 below.

The Klarna Card and One-Time Card

When you apply for the Klarna Card and the One-Time Card (available in the Klarna App), Klarna conducts a credit assessment of you, as we do for our other credit Services. If you have the Klarna Card, Klarna then continuously updates our credit assessment of you based on your interactions with Klarna.

We share information about you and the purchases you make when using the Klarna card with VISA and members of the VISA card network, as far as this is necessary to carry out the card transactions, prevent fraud, and follow applicable rules. If you renew your Klarna Card or receive a new one, we will transfer this information to VISA in order for VISA to inform third parties with whom you have stored your card details (for example for recurring transactions).

If you add your Klarna Card to a digital wallet, we may need to share your information with the digital wallet provider, in line with that provider’s privacy policy.

4.2 The Klarna User Experience Delivered under the Klarna Services Terms

To be able to deliver a smooth user experience, both before and after you have completed a purchase, Klarna offers the Services described below, and which are also described in more detail in the Klarna Services Terms. The use of these Services involves the following handling of your personal information:

Historical Transactions

We save information about the goods or services you purchase using our Services, or otherwise choose to give us access to, in order to display this information to you.

Autofill of your Information.

When we are able to identify you, we may autofill some information about you in the purchase flow, such as name, address, telephone number, email, date of birth and card details. The autofill is based on the information stored on your Klarna Profile. An example of when autofill is used is when you shop directly from the Klarna App.

Offers and Benefits

To be able to offer you benefits such as discounts, special events, pre-access to products, sales promotions, store offerings, sampling, giveaways, etc, we look at information about the interactions between you and Klarna (such as the number of purchases under a certain time period), your contact- and identification information, information on goods or services, and information about the interaction between you and stores.

The information will form the basis for Klarna’s marketing and customer analytics, business and method development, as well as statistics.

Within the offers and benefits program, Klarna and Klarna’s suppliers and subcontractors (on Klarna’s behalf), may use this information to communicate with you and deliver offers and benefits, via physical mail, text messages, email, social media and other digital channels. Klarna and its suppliers and subcontractors will not use any direct marketing channel for this purpose (e.g. email or text-messages) if you have opted out from direct marketing.

You can opt out from offers and benefits either by deregistering using the link provided in each email from us, or by contacting us, see Section 15 below.

Klarna AppIf you use the Klarna App, additional personal information (for example information uploaded by you) will be handled to provide the Services you choose to use within the Klarna App, as set out below. Furthermore, when you choose to redeem rewards or take part in specific deals, the providers of such offers may be able to deduce you use Klarna’s services. The personalisation of content forms an indivisible part of the Klarna App as an online shopping assistant.

• Personalized articles and ads: you will be able to see personalized articles and ads based on your previous purchases, contact and identification information, information on goods or services, information about the interaction between you and Klarna, and information about the interaction between you and stores, device information and service-specific information.
• Links that are sponsored: if you click on a link that is sponsored that promotes a product or service from a store you will be redirected to the store’s website through a third party, a so-called “affiliate network” (further explained in Section 6). The affiliate network might place a tracking technology on your device that contains the information that you clicked on a sponsored link in the Klarna App which is then used to track your visit to a store in order to calculate a potential commission to Klarna.
• Personalized Klarna overview: an overview is displayed, where you can view the status of your Klarna purchases and view your purchase history, access potential refunds, settle payments and extend your payment terms.
• Curated shopping collections: If you have shared with us information about what topics, products and services you are generally interested in, we will use this information to provide you with personalized shopping collections, where you may find products and services tailored to your interests.
• Delivery and parcel tracking: you may in some cases be able to track the route of your parcel.
• Possibility to “follow” stores: if you choose to “follow” a store, you receive information about campaigns connected to that store. Klarna will then automatically assess whether your purchases entitles you to discounts or other offers within that store’s ongoing campaign.
• Credit Services: we may offer you credit based on previous purchases.
• Shopping with the  One-Time Card: shopping through the Klarna App is a way of using Klarna’s payment methods in almost any store, through a One-Time Card. When you use the One-Time Card Klarna will collect information about your purchases and show them in the app.
• Customer service: when you contact the Klarna customer service through the Klarna App we will have access to the information you provide.
• The in-app web browser: The Klarna App contains a web browser in which you may access stores’ websites and online shops in order to then shop using Klarna’s payment methods also with stores that do not yet use our payment methods. Klarna collects information about how you use the browser in order to provide you with relevant deals and offers. Furthermore, websites you visit may set their own cookies and other tracking technologies on your device.
• Wishlist: You can choose to add products and services in the Klarna App to your Wishlist, in order to find them later, or track their prices. You may also share your Wishlist with other people such as friends and family, and they will then be able to see your profile picture and profile name. In some cases, if you are logged in to a store’s website, the link to a product or service you choose to add to your Wishlist may include personal information about you from that website, such as your email address.
• Profile picture: You can choose to upload a profile picture in the Klarna App, in which case this picture may be shown in various Klarna interfaces (for example in the checkout of a store that uses Klarna, or in the Klarna App). Klarna’s interfaces may also be embedded in stores’ apps. The picture may also be shown to others if you share your device with others (while using autofill through cookies), or if you choose to share content from your Klarna App with others. You may at any time erase your picture in the App or by contacting us.Browser ExtensionIf you use our browser extension, Klarna will process your data to deliver the service, which includes processing information about which websites/web domains you visit. Klarna processes information about the ecommerce websites/web domains you visit in order to identify deals, offer points and provide you with customised offers in the Klarna browser extension and mobile application. This processing is also done to allow you to create One-Time Cards directly in your browser on websites where this service is enabled. Information about non-ecommerce websites/web domains visited will not be stored by Klarna. Sensitive information gathered from you will not be used for any purpose other than to show you the current website in the browser. Websites you visit may also set their own cookies and other tracking technologies on your device.
• Personalized articles and ads: you will be able to see personalized articles and ads based on your previous purchases, contact and identification information, information on goods or services, information about the interaction between you and Klarna, and information about the interaction between you and stores, device information and service-specific information.
• Links that are sponsored: if you click on a link that is sponsored that promotes a product or service from a store you will be redirected to the store’s website through a third party, a so-called “affiliate network.” The affiliate network might place a tracking technology on your device that contains the information that you clicked on a sponsored link in the browser extension, which is then used to track your visit to a store in order to calculate a potential commission to Klarna.
• Personalized Klarna overview: an overview is displayed, where you can view the status of your Klarna purchases and view your purchase history, access potential refunds, settle payments and extend your payment terms.
• Curated shopping collections: If you have shared with us information about what topics, products and services you are generally interested in, we will use this information to provide you with personalized shopping collections, where you may find products and services tailored to your interests.
• Delivery and parcel tracking: you may in some cases be able to track the route of your parcel.
• Possibility to “follow” stores: if you choose to “follow” a store, you receive information about campaigns connected to that store. Klarna will then automatically assess whether your purchases entitles you to discounts or other offers within that store’s ongoing campaign.
• Credit Services: we may offer you credit based on previous purchases.
• Shopping with the One-Time Card: shopping through the browser extension is a way of using Klarna’s payment methods in almost any store, through a One-Time Card. When you use the One-Time Card, Klarna will collect information about your purchases and show them to you.
• Customer service: when you contact the Klarna customer service through the browser extension we will have access to the information you provide.
• Wishlist: You can choose to add products and services in the browser extension to your Wishlist, in order to find them later, or track their prices. You may also share your Wishlist with other people such as friends and family, and they will then be able to see your profile picture and profile name. In some cases, if you are logged in to a store’s website, the link to a product or service you choose to add to your Wishlist may include personal information about you from that website, such as your email address.
• Profile picture: You can choose to upload a profile picture in the browser extension, in which case this picture may be shown in various Klarna interfaces (for example in the checkout of a store that uses Klarna). Klarna’s interfaces may also be embedded in stores’ apps. The picture may also be shown to others if you share your device with others (while using autofill through cookies), or if you choose to share content from your browser with others. You may at any time erase your picture in the browser extension or by contacting us.

5. Consents and revoking consent for us to use certain personal information

As a condition of providing our credit Services, we will seek your irrevocable consent to disclose your credit information, for example to a credit reporting body (See Section 8 for more information). Without this consent, Klarna may be unable to supply our Services to you.

Furthermore, in certain specific cases where Klarna handles your personal information based on your consent (for example if you submit a Power of Attorney, allowing another individual to access your data, in case you provide us information indicating that you are a vulnerable customer, or in case you upload sensitive information into our Services), you can at any time revoke your consent for us to handle this information, either by contacting us or by deleting your uploaded information in the Klarna App.

If you are a customer of Klarna’s partner Commonwealth Bank of Australia (“CBA”), you may have consented to Klarna sharing information about your transactions and payments with CBA, a consent which you may also withdraw at any time.

6. Who might we share your personal information with?

When we share your personal data, we ensure that the recipient processes it in accordance with this notice, such as by entering into data transfer agreements or data processor agreements with the recipients. We may share your personal information with the categories of recipients listed below. Exactly which recipients we share your personal information with, and for which purposes, will depend on which Service you use. When we share your personal information, we take all reasonable contractual, legal, technical, and organisational measures to ensure that your personal information is treated with an adequate level of protection and in accordance with applicable law.

6.1 Suppliers and subcontractors 

Klarna may share personal information with the suppliers and subcontractors we use in order to provide our Services to you. Examples of such suppliers and subcontractors are software- and data storage providers, payment processing services, and business consultants.

6.2 Stores 

Klarna shares personal information with the stores you visit or purchase from (which may include the stores’ group companies if you have been informed about this by the store). This is done in order to allow the store to execute and administer your purchase, and administer your relationship with the store or its company group, for example by verifying your identity, send you the goods, manage questions and disputes, send relevant marketing and prevent fraud. The personal information shared with a store will be subject to the store’s privacy policies and practices.

6.3 Payment service providers (“PSPs”) 

PSPs provide stores and Klarna with services for accepting electronic payments through a variety of payment methods including credit card, and bank-based payments such as direct debit, bank transfers, etc. Some stores use PSPs with which they share your information for the processing of payments. This sharing is done in accordance with the stores’ own privacy policies. The store may also, for the processing and administration of payments, require us to share your information with the PSPs. Some PSPs also collect and use your information independently in accordance with their own privacy policies. This is for example the case if you use a digital wallet.

6.4 Credit reporting bodies and suppliers of identity lookups

We may need to verify your identity, for example under anti-money laundry legislation. To do this, we may share your identity information with third parties set out here.

If you apply to use a credit Service (see Section 4.1 above for information about our credit Services), we may share your credit information with credit reporting bodies ("CRBs"). Further information on how we collect, use and share your credit information, as well as the rights you have in relation to that credit information is set out in Section 8 below. 

6.5 Fraud prevention companies 

Your personal information may be shared with fraud prevention companies in order to verify the accuracy of the information you have provided us with, and to prevent criminal activities.

6.6 Klarna group 

Your information may be shared with companies within the Klarna group.

6.7 Commonwealth Bank of Australia (“CBA”)

If you are a customer of CBA, Klarna may share certain personal information with CBA, for example information about your payments and transactions based on your consent. CBA will handle your information in accordance with the purposes described in its privacy collection notice and privacy policy.

6.8 Social media companies 

If you contact us through social media such as Facebook or Twitter, your information will be recorded and processed by those companies, in accordance with their privacy policies. We might also share your email address and device information when using our Services with social media companies to provide you with personalized ads (retargeting) in accordance with their privacy policies.

6.9 A person holding a power of attorney of your affairs 

Klarna will share your information with a person holding a power of attorney from you, allowing the person holding the power of attorney to receive such information. This sharing will be done based on your consent.

6.10 Google

When you use Google Maps in the checkout (for example by searching for your address in the address field) or the Klarna App, Google will process your information subject to Google Maps’/Google Earth's Terms of Service and Privacy Policy. Furthermore, when you use the Klarna App through a web browser, Google will collect your device information through its reCAPTCHA service implemented there, sometimes combined with any information you enter into the reCAPTCHA service. Google will process this information in line with its own privacy policy.

6.11 Authorities 

Klarna may disclose necessary information to authorities such as the police, tax agencies or other authorities if we are required to do so by law, or under some circumstances if you have requested us to do so. One example of such legally required disclosures is disclosure for purposes of anti-money laundering and counter terrorist financing.

6.12 Logistics and transportation companies 

Klarna may share your information with logistics and transportation companies that deliver the goods you have ordered, if you have opted in to parcel tracking. Examples of information we share are contact- and identification information and tracking number. Please note that the logistics and transportation companies process your information in accordance with their own privacy policies.

6.13 Partners within the Personal Finance Service and the Offers and benefits program

If you choose to take part of offers and benefits which Klarna provides within the Personal Finance Service or through the Offers and benefits program, Klarna may share the personal information that is necessary to enable you to access offers made in cooperation with our partners (this includes the fact that you are a customer of Klarna). Which personal information is shared is presented in connection with every offer.

6.14 Debt Collection Agencies 

Klarna may share your information when selling, or assigns to collect, unpaid debts to third parties, e.g. to debt collection agencies. This sharing of personal information is based on our legitimate interest in collecting and selling debts. The debt collection agencies may process your personal information in line with their own privacy policies, or on Klarna’s behalf. The debt collection agencies may also report your unpaid debt to credit reference bodies which may affect your credit rating and your ability to obtain future credit.

6.15 Affiliate Networks

Klarna may share the information that you have clicked on a link that is sponsored (i.e. a link that promotes a store, product or service with so-called “affiliate networks”. This sharing takes place when you click on a link that is sponsored as you will then be redirected to the store’s website through the “affiliate network”. The affiliate network might place a tracking technology on your device that contains the information that you clicked on such a link in one of Klarna’s interfaces, in order to track your visit to a store in order to calculate potential commission to Klarna. The affiliate networks may process your personal data in line with their own privacy notices.

6.16 Divestment

• In the event that Klarna sells or buys any business or assets, Klarna may disclose your personal information to the prospective seller or buyer of such business or assets.
• If Klarna or substantially all of its assets are acquired by a third party, personal information about Klarna’s customers may be disclosed and shared.

7. Do we disclose your personal information outside Australia?

We always strive to store your personal information within Australia. In certain situations, such as when we share your personal information with a Klarna group company or a supplier or subcontractor located outside Australia, your personal information may however be transferred to, and disclosed in, a destination overseas. If the store where you shop is located outside Australia, our sharing of your personal information with the store will also mean that your information is transferred overseas.

We ensure that an adequate level of protection is maintained, and that suitable safeguards are adopted in line with applicable Australian privacy law requirements when we transfer your information outside Australia.

You can find out which countries your information may be sent to here.

8. Credit information policy and your rights in relation to your credit information

When you use a credit Service (as described in Section 4.1), we will collect credit information about you. The types of credit information we collect may include information about:

• your identity;
• the type and amount of credit you have, such as through loans and credit cards and information about applications for credit that you have made where credit providers have requested your information from a credit reporting body (a “CRB”, as defined in Section 6);
• your repayment history and defaults; and
• whether you have committed fraud or a serious credit infringement.

We will obtain this information in a credit report (including a credit score) about you from a CRB. We will use this information, combined with information we already hold about you, to assess your creditworthiness and to decide whether to offer you credit. We may also use this information to manage our credit arrangements with you including for collection purposes.

If we provide you with a credit Service and you do not meet your repayment obligations, or you commit a serious credit infringement, we may pass this information on to a CRB. CRBs include this information in their reports to assist other credit providers to assess your creditworthiness.

The CRB with which we cooperate in Australia is listed here. You can obtain a copy of its privacy policy on its website.

We hold your credit information in the same way as other types of personal information that we hold about you (as described in Section 9 below). We may also share this information with our related bodies corporate and service providers with entities overseas (see Section 7 above).

You may request access to, or correction of, your personal information including credit information. See Section 11 below for more details or Section 12 about how you can make a complaint about our handling of your credit information including any concerns about our failure to comply with the relevant provisions of the Privacy Act 1988 relating to credit information or the Credit Reporting Code.

You also have the following rights in relation to your credit information:

• credit providers like us can ask CRBs to use your credit information to pre-screen you for direct marketing purposes. If you do not want CRBs to use your information in this way, you may opt out by contacting us using the details in Section 15 below.
• if you think you have been or could be a victim of fraud, you can ask the CRB not to use or disclose your credit reporting information.

9. How do we hold your personal information?

We hold your personal information in a combination of electronic and hard copy files. Electronic information is stored with a third-party data storage provider.

We may combine personal information we receive about you with other information we hold about you. This includes information received from third parties.

We take all reasonable and appropriate steps (including organisational and technological measures) to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. Where we store your personal information with a third-party data storage provider, we require them to keep it secure and only use or disclose it for the purpose for which it was provided.

10. How long do we process your personal information?

We will handle your personal information for the time period needed to fulfil the respective purpose of our processing. These purposes are described in this Privacy Policy. This means that even though we stop processing your personal information for one purpose, we may still need to keep your personal information, if the information is needed for another purpose, using it only for that other purpose. In particular:

• For as long as you have accepted our Klarna Services Terms, and until you terminate those terms (by contacting us or by instructing us to delete information, for example by way of a right to erasure request), we will process the personal information we need to be able to deliver the Services to you, including but not limited to information relating to your previous purchases.
• We may contact you for marketing purposes for up to a year after your last interaction with us, if you have not opted out from this.
• We process the personal information included in credit lookups for the purpose of new credit assessments for a time period of 90 days, following the date that the lookup was done.
• We process the recordings of telephone conversations for a time period of 90 days for quality assurance purposes.

11. Accessing and correcting your personal information

We will endeavour to ensure that the personal information collected from you is up to date, accurate and complete.

You may request access to, or correction of, the personal information we hold about you at any time by contacting us using the contact details in Section 15 below. We will need to verify you before meeting your request. Subject to any applicable exceptions or requirements, we will provide you with access to the personal information you request within reasonable time and usually within 30 days. If we decide to refuse your request we will tell you why in writing and how to complain.

You can also access and update certain personal information in the Klarna App.

12. Complaints

You can make a complaint in writing to us using the contact details in Section 15 below. We will need to verify your identity. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) via the OAIC website, www.oaic.gov.au. Furthermore, you can always contact the Australian Financial Complaints Authority (AFCA) using the contact details below;

www.afca.org.au

Email; info@afca.org.au

Phone; 1800 931 678 (free call)

Letter; Australian Financial Complaints Authority: GPO Box 3, Melbourne VIC 3001.

13. What about cookies and other tracking technologies?

To deliver a tailored and smoooth experience, we use cookies and similar tracking technologies in our online interfaces, such as our website, the Klarna App, and the checkout of stores that cooperate with Klarna. You can find more information about the tracking technologies we use below and in the respective interface.

Most web browsers enable you to decline or block tracking technologies through the browser settings, and you can also delete any tracking technologies stored on your device at any time. However this may limit certain functionality of our Services.

Tracking technologies in the checkout of a store

Klarna uses cookies in the checkout of a store in order to provide our Services and keep them secure.

Tracking technologies when using the Klarna AppOur App contains various tracking technologies necessary to keep it safe and secure. Furthermore, we also use tracking technologies for analytics purposes, personalisation of content, and marketing. We may also share personal information collected from tracking technologies with advertising networks for marketing purposes.

14. Updates to this Privacy Policy

We constantly work to improve our Service offerings, in order for you to get an even smoother user experience. This includes both changes in existing Services and new Services over time. It’s therefore important that you read this Privacy Policy each time you use a Klarna Service, since the processing of your personal information can differ since you last used one of our Services.

15. Contact details

Klarna Australia Pty Ltd (ABN 82 635 912 579) is located at: Level 16, 175 Pitt  Street, SYDNEY NSW 2000, Australia.

Klarna has a special team of customer service specialists for privacy matters. You can always reach them at dataprotection@klarna.com.au.

Visit www.klarna.com/au/ for further information on Klarna