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LEGAL

Privacy Policy

Effective date: [date of publication TBC]

Legal entity: Kaibr is provided by Kaibr Technologies Pty Ltd (ACN 704 097 870, ABN 66 704 097 870).

The short version Draft

  • With your consent, we access your bank data through Fiskil, an accredited open banking provider. Today that access is read-only.
  • We use your data to run Kaibr’s AI Money Agent and your account. We don’t sell it, and you can stop sharing at any time.
  • You can ask to see or correct your information, or complain to us or the OAIC.
On this page
  1. 1. About this policy
  2. 2. Information we collect
  3. 3. How we use your information
  4. 4. The AI Money Agent
  5. 5. Card-linked cashback with PokitPal
  6. 6. Bank data and the Consumer Data Right
  7. 7. Who we share information with
  8. 8. Overseas disclosure and retention
  9. 9. Security
  10. 10. Marketing
  11. 11. Access and correction
  12. 12. Complaints
  13. 13. Contact us
  14. 14. Spot
  15. 15. Children
  16. 16. Changes to this policy

1. About this policy #

This Privacy Policy explains how Kaibr ("Kaibr", "we", "us", "our") collects, uses, discloses and protects your personal information when you use the Kaibr app for iPhone, our website and our related services (the "Service").

We handle personal information under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). When we handle bank data shared through the Consumer Data Right (CDR), we also follow the Competition and Consumer Act 2010 (Cth), the Competition and Consumer (Consumer Data Right) Rules 2020 (CDR Rules) and the CDR Policy of Fiskil Pty Ltd, as explained in section 6.

2. Information we collect #

  • Account and contact details: your name, email address, sign-in details and preferences.
  • Bank data (CDR data): account names and types, balances and transaction details from the bank accounts you choose to connect. We collect this only with your CDR consent, through Fiskil.
  • Information we derive from your bank data: cleaned-up merchant names, spending categories, summaries, insights, alerts and nudges, and the actions you take on them. We treat this as CDR data.
  • Cashback information: if you choose to use card-linked cashback, the details described in section 5.
  • Subscription information from Apple: your subscription status (for example free trial, active, cancelled or refunded), product, purchase and renewal dates and App Store transaction identifiers. We do not receive or store your card or other payment details for your subscription. Apple holds them.
  • Device and usage information: device type, operating system, app version, IP address, log and analytics events, and push notification tokens and settings.
  • Support communications: messages you send us and our replies.

We collect only what we reasonably need to provide the Service. We never ask for, collect or store your online banking password.

3. How we use your information #

We use personal information to:

  • provide the AI Money Agent, including insights, briefs, alerts, nudges and budgeting tools (section 4);
  • operate your account and your subscription status;
  • provide card-linked cashback if you choose to use it (section 5);
  • verify your identity when you sign in, and keep the Service secure;
  • fix problems and improve the Service, using aggregated or de-identified information where practicable (we use CDR data for this only where the CDR Rules and your consent allow);
  • handle questions, complaints and requests;
  • comply with the law; and
  • send service messages and, where you have agreed or the law allows, marketing (section 10).

We do not sell your personal information. We do not use CDR data for direct marketing.

4. The AI Money Agent #

What it does. Kaibr's AI Money Agent uses the bank data you share to clean up merchant names, categorise your transactions, explain your spending and send you insights, alerts and nudges. Amounts and totals are calculated by our own systems. The AI model explains them in plain language.

Not advice. The AI Money Agent gives general information about your own spending and provides budgeting tools. It is not financial product advice or credit advice. It does not recommend any bank account, loan, credit card, insurance, superannuation or investment product, and it does not consider your objectives, financial situation or needs. AI can make mistakes. Check important information against your bank records.

Where processing happens. Our AI model runs on Amazon Web Services (AWS) infrastructure in Australia (Sydney, with Melbourne as a backup). Your bank data, and information derived from it, is stored and processed in Australia and is not sent overseas. [AWS approval by Fiskil as an outsourced service provider: confirm before publication.]

No training. We do not use your bank data to train or improve AI models, whether ours, AWS's or the model developer's.

Automated decisions. Our systems use your bank data automatically to choose which insights and nudges to show you and when to show them, and to put your transactions into categories. These are automated processes, but they do not decide whether you can get a product, a price or credit, and they do not otherwise make decisions that significantly affect your rights or interests. You can change categories and turn nudges off at any time. If we start using automated decisions that could significantly affect you, we will update this policy before we do.

5. Card-linked cashback with PokitPal #

Kaibr offers card-linked cashback through our partner PokitPal [PokitPal legal entity name and ABN TBC]. Using cashback is optional.

  • Linking your cards. You can choose to link one or more of your existing debit or credit cards. You do not need a new card. [Card schemes supported TBC.]
  • Information shared with PokitPal. When you link a card, the card details you enter and an identifier for your Kaibr account are shared with PokitPal [and its card-linking provider TBC] so that eligible purchases can be matched to offers. PokitPal then receives details of purchases made with your linked cards at participating merchants, such as merchant, amount and date, and tells us about the cashback you have earned. [Exact data fields, and whether PokitPal receives your name and email, TBC against the PokitPal agreement.] We do not share your CDR bank data with PokitPal.
  • PokitPal's own handling. PokitPal handles the information it receives under its own privacy policy [link TBC].
  • Unlinking. You can unlink a card at any time in the app. Unlinking stops new purchases being matched. Information already shared is handled under PokitPal's privacy policy and our retention rules (section 8).
  • Overseas. [Whether PokitPal or its providers store or process card or purchase information outside Australia, and in which countries: TBC.]

6. Bank data and the Consumer Data Right #

6.1 How it works. Kaibr is not an accredited data recipient. Kaibr is a CDR representative of Fiskil Pty Ltd (ABN 89 646 260 728), an accredited data recipient (accreditation number ADRBNK000246). When you connect a bank account, Fiskil collects your bank data from your bank at our request and discloses it to us so that we can provide the Service. Your bank never gives us your banking password.

6.2 Read-only access. Our access to your bank data is read-only. We can see the account information you agree to share. We cannot make payments, move money or change your accounts with this access.

6.3 Fiskil's CDR Policy. We follow Fiskil's CDR Policy for all CDR data we receive and for information derived from it. It explains how CDR data is collected, used, disclosed, corrected and deleted, and how to complain: https://www.fiskil.com/legal/cdr-policy. If this policy and Fiskil's CDR Policy differ on how CDR data is handled, Fiskil's CDR Policy applies.

6.4 Your consent. We collect CDR data only with your express consent. Before you connect, our consent screen shows what data we ask for and why, how long the consent lasts (no more than 12 months), any service providers that may access the data, and how to withdraw. You then confirm sharing with your bank, and you receive a CDR receipt.

6.5 Managing and withdrawing consent. You can see your active consents and withdraw them at any time in the Kaibr app, through your bank's data sharing dashboard, or by contacting us or Fiskil. We remind you at least every 90 days that a consent is still active.

6.6 Deletion. When your consent is withdrawn or expires, Fiskil stops collecting your data and we stop using it. In line with Fiskil's CDR Policy, CDR data that is no longer needed, including information derived from it, is deleted rather than de-identified. We keep only the records the CDR Rules or other laws require, such as records of your consents.

6.7 How we use and share CDR data. We use CDR data only to provide the Service you asked for. We do not sell it, and we disclose it only to Fiskil and to service providers named in the consent flow, such as AWS.

6.8 Correction. You can ask us or Fiskil to correct your CDR data.

6.9 Your subscription is separate. Connecting a bank is separate from your App Store subscription. Withdrawing CDR consent does not cancel your subscription, and cancelling your subscription does not withdraw your CDR consent. Apple does not receive your CDR data.

7. Who we share information with #

  • Fiskil Pty Ltd: our CDR representative principal, which collects your bank data at our request and manages consent records (Australia).
  • Amazon Web Services: hosting, storage and AI processing (Australia only) [AWS contracting entity TBC].
  • Apple: sells and bills your subscription through the App Store and tells us your subscription status. Apple does not receive CDR data. Apple may process information outside Australia under its own privacy policy.
  • PokitPal: card-linked cashback, if you use it (section 5).
  • Other service providers: email, analytics, push notifications and support tools, which do not receive CDR data [names and locations TBC].
  • Advisers, regulators and others where the law requires or allows it, including the OAIC and the ACCC.
  • A buyer or successor in a merger, sale or restructure, subject to equivalent privacy protections and the CDR Rules.

8. Overseas disclosure and retention #

Overseas. We do not send CDR data, or information derived from it, outside Australia. Some of our other service providers, and Apple, may store or process non-CDR personal information outside Australia. [List of countries TBC before publication.] Where we disclose personal information overseas, we take reasonable steps to make sure it is handled in line with the APPs.

Retention. We keep personal information only for as long as we need it for the purposes in this policy or as the law requires. CDR data is kept only while your consent is current and the data is needed, and is then deleted (section 6.6). Subscription and tax records are kept for as long as tax and accounting laws require.

9. Security #

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, change or disclosure. CDR data receives the additional information security protections the CDR Rules require. No system is completely secure, so please protect your device and sign-in details.

10. Marketing #

We send service messages you need to use Kaibr. We send marketing only where you have agreed or the law allows, and you can opt out at any time using the unsubscribe link or by contacting us. Nudges are part of the Service, not marketing, and you can turn them off in the app.

11. Access and correction #

You can ask for access to the personal information we hold about you, and ask us to correct it, by contacting us (section 13). We will respond within 30 days. If we refuse a request, we will tell you why in writing, unless the law says we do not need to, and how to complain. There is no charge to ask. For CDR data, you can also ask Fiskil.

12. Complaints #

If you have a privacy or CDR complaint, please contact us first (section 13).

  • We will acknowledge your complaint within 1 business day.
  • We aim to resolve it within 30 calendar days. If we need longer, we will tell you why and keep you updated.

You can also complain about CDR data to Fiskil's Complaints Officer at complaints@fiskil.com.au.

If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992.

Unresolved CDR complaints may be taken to the Australian Financial Complaints Authority (AFCA) under Fiskil's AFCA membership, as described in Fiskil's CDR Policy.

[AFCA, for Kaibr's own services: show only once membership is confirmed. "If you are not satisfied with our response, you can contact the Australian Financial Complaints Authority (AFCA): www.afca.org.au, 1800 931 678."]

13. Contact us #

Privacy enquiries, requests and complaints:

14. Spot #

[PLACEHOLDER: show only if Spot is live. "Spot loans are provided by Kaibr Capital Pty Ltd under separate Spot terms and its own privacy and credit reporting policy."]

15. Children #

Kaibr is for people aged 18 and over. We do not knowingly collect personal information from children under 18.

16. Changes to this policy #

We may update this policy from time to time. The version on our website shows its effective date. We will tell you about significant changes by email or in the app.

Questions? Contact us →