Privacy policy

1.Who we are

Our apps for iPhone, iPad and Mac are built and operated by Eagles Flight Solutions (ABN 61 200 390 691), a Metro Advisory business (‘Eagles Flight Solutions’, ‘we’, ‘us’, ‘our’). This policy explains how we handle personal information in connection with our apps, this website and our support channels.

It covers Eva Ur Money Buddy, Florins Crypto, Freehold, SimplifiedRetirement and DemographyStudio. Provisions about a particular feature apply only where that feature is available in the app you use.

2.The law we follow

We handle personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) in Schedule 1 to that Act.

Where an app lets you connect financial accounts and you choose to connect them, data received through the Consumer Data Right (CDR) is also handled under Part IVD of the Competition and Consumer Act 2010 (Cth) and the Competition and Consumer (Consumer Data Right) Rules 2020 (Cth). These add protections on top of the Privacy Act.

3.Information stored on your device and in your private cloud

The following information is created or received by the app and stored under your control. It is kept on your device by default and, if you turn on sync in settings, in a private database in your own cloud account (for example, iCloud):

• Financial account data: account names, balances and transactions shared with your consent through the CDR (read-only)
• Content you create: budgets, categories, goals, portfolios, property models, retirement scenarios, population models and notes
• Files you import: for example, exchange CSV files
• Derived insights: forecasts, calculations and patterns worked out on your device.

We have no technical ability to access, read or recover this information. Because we do not collect or hold it, it is not ‘held’ by us under the Privacy Act 1988 (Cth). It stays in your custody, protected by your device passcode and cloud account credentials.

4.Information we hold

The personal information we collect and hold is limited to:

• Support messages: your name, contact details and what you tell us when you contact support
• Opt-in diagnostics: aggregated crash and performance reports that Apple shares with us only if you turn on sharing in your device settings. They contain no financial records
• Purchase information: Apple processes all payments. We receive sales reports from Apple that do not identify you
• Website analytics: if we measure visits to this website, we use aggregate counts only and ask for your consent first.

We do not collect sensitive information, such as health or biometric information. Please do not include it in support messages.

5.Why we use it

In line with APP 6, we use the limited information we hold to answer your support requests, keep our apps reliable and secure, improve them, and meet our legal obligations.

We do not sell personal information. We never use financial data for advertising. We could not, because we do not have it.

6.Who we share it with

We disclose the information we hold only to:

• service providers who support our operations under contract (for example, an email provider), who may use it only to provide services to us
• professional advisers and regulators, where the law requires or allows it
• a buyer of our business, if it is sold, on terms that keep the protections in this policy.

Our support email is hosted by Proton AG in Switzerland. Where a provider handles personal information overseas, we take reasonable steps under APP 8 to make sure it is handled consistently with the APPs. We will list any further countries in this policy.

We cannot disclose your financial data in any circumstances, because we do not hold it.

7.Consumer Data Right data

Financial data shared through the CDR is collected only with your express, informed consent. It is delivered to and processed on your device, and used only for the purposes you agreed to.

The consent dashboard in the app shows every active consent and lets you withdraw any of them at any time. When a consent expires or you withdraw it, the related data is deleted from your device and private cloud in line with the CDR Rules, unless the law requires us to keep it.

8.How we protect it

Under APP 11 we take reasonable steps to protect the information we hold. Our apps are also designed to protect the information you hold:

• on-device data is stored in an encrypted database protected by your device’s hardware security and passcode
• private-cloud data is encrypted in transit and at rest in your own cloud account, which we cannot access
• all network connections use TLS 1.2 or higher
• our own systems use multi-factor authentication, least-privilege access and logging, and we destroy or de-identify information we no longer need.

9.Automated decisions

Our apps make calculations and projections on your device to help you understand your position. They do not make decisions that could significantly affect your rights or interests, and we do not use your personal information to make automated decisions about you.

10.Data breaches

We keep a data breach response plan for the limited information we hold. If a data breach is likely to result in serious harm, we will notify the people affected and the Office of the Australian Information Commissioner (OAIC) under the Notifiable Data Breaches scheme in Part IIIC of the Privacy Act 1988 (Cth).

11.Access and correction

Your financial data is already in your hands. You can view it in the app and, where the app offers it, export it from settings at any time.

For the information we hold, you can ask for access under APP 12 and correction under APP 13 by contacting our privacy officer. We will respond within 30 days, free of charge. If we refuse a request, we will tell you why in writing and explain how to complain.

12.Marketing

We send marketing messages only with your consent, in line with the Spam Act 2003 (Cth). Every message includes a working unsubscribe option. Opting out never affects your use of our apps.

13.Children

Our apps are not directed to children and are for people aged 13 or over. We do not knowingly collect personal information from anyone under 13. If we learn that we have, we will delete it.

14.Complaints

If you think we have mishandled your personal information, contact our privacy officer first. We will acknowledge your complaint within 7 days and aim to resolve it within 30 days.

If you are not satisfied with our response, you can complain to the OAIC at oaic.gov.au or on 1300 363 992.

15.Changes to this policy

We review this policy at least once a year and whenever our practices change. We will tell you about material changes in the app before they take effect. Every version is dated and archived, and we can give you a previous version on request.

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