In handling your information, we are bound by, and comply with, the Privacy Act 1988, the Australian Privacy Principles (APPs) and the Privacy Credit Reporting Code (Code).
WHAT IS PERSONAL INFORMATION, CREDIT INFORMATION AND CREDIT-ELIGIBILITY INFORMATION?
When we refer to personal information, we mean information from which your identity is reasonably apparent, which may include information or an opinion about you. The personal information we hold about you may also include credit-related information.
Credit information, which is information which includes your identity; the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information, default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information and publicly available information.
Credit eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.
The kinds of personal information we may collect about you include your name, date of birth, address, account details, occupation, and any other information we made need to identify you. When you use our website or mobile applications, we may collect information about your location or activity, including IP address, telephone number and whether you have accessed third party sites, the date and time of visits, the pages that are viewed, information about the device used, and other user location information.
If you are applying for finance or providing a guarantee, we may also collect the ages and number of your dependants and cohabitants, the length of time you have resided at your current address, your employment details, and proof of earnings and expenses. If you apply for any insurance product through us, we may collect information about what is being insured, the beneficiaries, and your health information, including medical and lifestyle information from you or your health professionals. We will only collect health information from you with your consent.
We collect information from, and about, you to, as appropriate:
· respond to your enquiries about our finance products or insurances we can source for you
· assess your credit application and provide you with the consumer or commercial finance you require from us
· assess the application for finance made by a company of which you are a director
· assess your application to guarantee the repayment of finance we are considering providing
· manage that finance
· provide customer support
· promote our finance products
· manage any complaints
· manage any business arrangements under which we provide or receive goods or services
We also use the information we collect to:
· verify your identity
· manage your account
· develop new products, policies and procedures
· undertake market research
· obtain legal and compliance advice about our obligations
· manage our risk
· meet our regulatory and legal obligations
The information we collect may include personal identification, contact details, financial information, lending and default history, banking details, bank statements, personal and trade references and employment or business history, depending on the relationship you wish to have with us. If you choose not to provide this information, our ability to assist you may be restricted.
Wherever possible, we will collect your information directly from you, or from your broker, should you wish to apply for finance. We may obtain information about you from a third party, such as your accountant, lawyer, employer or a credit reporting body, for a particular purpose. Wherever possible we will tell you who we need to contact and why.
We may also collect information from you if you choose to use our website to communicate with us. We will collect the information you provide through our interactive facilities, such as customer enquiry, online finance application or comment forms.
In some circumstances, brokers, dealers, accountants, referees, external dispute resolution schemes, your agents and government bodies may provide us with your information. The circumstances in which third parties provide us with information include purchase or service requirements, employment or finance applications, account management and complaints.
We take a range of measures and reasonable steps to protect any information we collect so it will be safeguarded from misuse, loss, unauthorised access, use, disclosure or modification. We may disclose and store your information overseas to our service providers who are located or hold data overseas including in the United Kingdom and New Zealand. For more information on the countries to which this information is disclosed, please contact us. We also use cloud computer services and require their security measures to meet Australian privacy standards.
The law may require us to retain your information for a period of time after our business dealings have finished. It is securely stored and disposed of, or de-identified, when no longer required.
When you visit our website, our ISP host records a range of information, including your server address, domain name, the date and time of the visit and the pages viewed.
Information collected about your visit to our site is retained for statistical and website development reasons and is not in a form which would enable us to identify you.
When visiting our site, you will not be required to provide us with any information unless you request information about our finance or respond to a promotion. If you do, we will ask you to provide contact details along with other information required to respond to your contact with us.
We may also retain that information provided for product planning purposes. It may also be used for direct marketing purposes unless you tell us you do not wish to receive marketing material.
We use your information to assess and provide you with the finance you require, consider your suitability to be a guarantor and perform other functions and activities associated with managing our relationship.
Those functions and activities can include our internal administration, credit assessment, account management including any necessary collection activities, product or service development, compliance audits/reviews, marketing, complaints management, planning and research requirements as well as future offers of finance to you.
Where you, as an individual, apply for finance with us, or agree to act as a guarantor, you authorise how we may collect, use, hold and disclose your information in the Privacy Statement and Consent we ask you to sign before we consider your application for credit or to be a guarantor.
We will disclose your information to third parties only as the Privacy Act permits and where there is a valid reason to do so. All third parties must use your information only for the specific purpose for which we supply it.
Third parties may include:
· Prospective funders or other intermediaries in relation to your finance requirements
· Employees, contractors, agents, auditors and advisers
· Other organisations that are involved in managing or administering your finance, such as third party suppliers, printing and postal services, call centres, lenders, mortgage insurers, trade insurers and credit reporting bodies
· Your agents, including your dealer or broker, where required
· Any person who represents you
· Other guarantors or borrowers (if more than one)
· Insurers, insurance brokers and insurance assessors
· Service providers who assist us promote our services and/or to manage our business, including auditors and lawyers
· Debt collection agencies
· Referees, where authorised
· Companies to which we are related
· Government authorities and law enforcement agencies, as required by law only
· Investors, agents or advisers, trustees, rating agencies or any entity that has an interest in your finance or our business
· A dispute resolution body of which we are a member
· Other business partners and their agents or contractors
· Government authorities which hold your driver’s licence and/or motor vehicle registration information in order to confirm your address details.
Prior to disclosing any of your information to another person or organisation, we make sure there are appropriate privacy, data handling and security arrangements in place to protect your information.
We do not sell your information to other organisations for marketing purposes.
We may also provide your information to, and receive your information from, a credit reporting body (CRB). We may:
· disclose your information to Equifax and/or Illion, a credit reporting body for credit assessment or collections purposes;
· obtain your consumer or commercial credit report;
· use information provided by the CRB for credit assessment or collections purposes, including:
o your name, address and date of birth;
o your employment history;
o current and previous credit account history;
o repayment history;
o default history;
o any court proceedings – summons, judgement and bankruptcy actions;
o serious credit infringements history, covering fraudulently obtaining, or attempting to obtain finance or shown an intention to avoid repayment obligations; and
o your credit eligibility information;
· provide the CRB with your repayment history;
· notify the CRB of any overdue payments, provided they are more than 60 days overdue, we have attempted to collect the payment and we have notified you of our intention to do so;
· notify the CRB of a serious credit infringement if we have reasonable grounds to believe you fraudulently obtained, or attempted to obtain, credit from us or that you have shown an intention to evade your obligations under the contract with us (we will only do this if we have not been able to contact you over a 6 month period); and
· ask the CRB to assess your eligibility to receive direct marketing material from us.
Any information shared with, or by, a CRB is held in electronic form, trackable through the CRB or our systems by time, date, account and user.
When you authorise us to provide you with documents electronically, we will provide them by email or SMS in accordance with the information provided.
You can cancel your authorisation at any time by notifying us in any of the ways shown in our Contact section (below).
From time to time, we may use your information to inform you about our products and services including special offers. We may also send you material relating to joint promotions with dealers and our other business associates of our respective products and services.
You may at any time opt out of receiving marketing information by phoning us on 1300 972 538 or by writing to us at email@example.com. If we are sending you direct marketing by email, you may also use the unsubscribe function. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
UPDATING YOUR INFORMATION
It is important to us that the information we hold about you is accurate and up-to-date. During the course of our relationship with you, we may ask you to inform us if any of your information has changed.
If you wish to make any changes to your information, you may contact us. We will generally rely on you to ensure that the information we hold about you is accurate or complete.
INFORMATION ACCESS AND CORRECTION
You can access the information we hold about you by contacting us in any of the ways shown in our Contact section (below).
Depending on the type of request that you make, we may respond to your request immediately. Otherwise, we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your information, for example, if the information relates to existing or anticipated legal proceedings, if your request is vexatious, or if the information is commercially sensitive.
If we deny you access to the information we hold about you, we will explain why.
If any of the information we hold about you is incorrect, inaccurate or out-of-date, you may request that we correct the information by phoning us on 1300 972 538 or by writing to us at firstname.lastname@example.org.
If appropriate, we will correct the information at the time of your request. Otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected your information within 30 days.
We may need to consult with other finance providers or CRBs or entities as part of our investigation.
If we refuse to correct information, we will provide you with our reasons for not correcting the information.
You can also access the information the CRB holds about you by contacting them for a copy of that information at:
Mailing address: GPO Box 964. North Sydney, NSW 2059
Phone: 13 8332
Phone: 13 2333
Business without identifying you
In most circumstances, it will be necessary for us to identify you in order to successfully do business with you. However, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information (for example, if you make general inquiries about interest rates or current promotional offers).
We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.
Complaints and Concerns
Please contact us if you have any complaints or queries about how we manage your information, or you no longer wish to receive marketing materials. You can contact us by mail, phone or email, as listed below.
If you lodge a complaint, our Internal Dispute Resolution officer will investigate your complaint. We will commence the investigation within 2 days and provide you with a response within 14 days. We will seek your agreement to a longer time if it is needed. We will keep you informed of the investigation process by phone or email at least once a week and provide you with a written response to your complaint within 30 days.
If you do not accept our response, you may take the compliant to our External Dispute Resolution Scheme, AFCA.
AFCA provides fair and independent financial services complaint resolution that is free to consumers and can be contacted on the below details;
Telephone: 1800 931 678
Writing to: GPO Box 3, Melbourne VIC 3001
Alternatively, you may make a complaint to the Privacy Commissioner who can be contacted at either www.oaic.gov.au or by phone on 1300 363 992.
Postal Address: Locked Bag 2080 North Ryde BC NSW 1670
Phone: 1300 972 538