Privacy Policy

Personal information is any information or opinion about you that may identify you or that may make you reasonably identifiable. The personal information we collect may include general information about you such as your name, contact details (e.g., your postal and email address, or mobile phone number), date of birth and financial information such as your income, savings, borrowing history and the reason you may be obtaining finance from us.

When you make an order for a product or service offered by us, we will collect your payment information (such as your bank account or credit card information). This information is collected and stored by a third-party payment processing company (e.g. Stripe). The use and storage of that information is governed by the third party payment processor's applicable privacy policy.

If you complete a survey or questionnaire provided by us, we will collect the personal information you use in your responses, or when you provide us with feedback and participate in promotions. We may also collect sensitive information (including health information) about you and this may include any information you tell us about any vulnerability you may have.

We additionally collect credit information and credit eligibility information (credit-related information) about you. The types of credit information we may collect from you include copies of your government issued identification, your employment history, consumer credit liability information, repayment history, whether you have or are suffering from financial hardship, credit enquiries, default information and personal insolvency information. We may also obtain information from Credit Reporting Bodies (CRBs) about you. This information is credit eligibility information and may include information about your credit worthiness, including a credit assessment, an unsuitability assessment and any credit scores about you.

We collect most personal information from our engagements directly with you. This may occur when you apply for our services (such as by completing an application form), speak to us over the phone, or otherwise communicate with us electronically or in person.

We may keep records of our interactions with you for the purpose of staff training, for security reasons, and/or to assist with our complaint handling processes.

In some circumstances, we may collect personal information from publicly available sources (such as public registers or publicly accessible online information), where it is lawful and relevant to the services we provide.

We may, in certain circumstances, need to obtain personal and credit-related information about you from our related businesses, authorised representatives and credit representatives and/or from third parties, including CRBs. We may need to do this where we are required to verify your identity, undertake customer due diligence, prevent or detect money laundering or terrorist financing or otherwise where we are required or authorised by law. The third parties we collect this information from may include banks, financial advisers, family members, your employer, medical practitioners, CRBs, government authorities or from other publicly available sources of information.

Where you provide us with personal information about another individual (for example, a guarantor or related party), you must ensure that they are aware of this Privacy Policy and, where required, have consented to their information being collected, used and disclosed by us.

Where permitted by law, we may record telephone calls between you and us. Call recordings are used for verification, compliance, dispute resolution, quality assurance and staff training purposes. You will be notified where a call is recorded and given the opportunity to request that the call not be recorded where reasonably practicable.

We use credit-related information and other personal information we have collected from you to arrange or provide credit and other services to you.

We act as a credit assistance provider and broker. We do not provide credit. Where you apply for credit through us, we disclose relevant personal and credit-related information to lenders and other credit providers for the purpose of assessing your application. Credit decisions are made by those lenders, not by us.

For example, we may use this information to provide you with a requested product or service, to verify your identity and undertake customer due diligence (particularly where we are required to do so under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth)), to assess or process an application, to assist you with managing a complaint or dispute, or for research and the training of our staff.

We may use your personal information for marketing and other similar promotional purposes such as:

• to send you our newsletter, or other marketing materials related to the services that we provide that we think may be of interest to you;
• to reply to your questions, inquiries or customer service requests, or to send you notices, updates or administrative messages;
• to monitor and analyse trends, usage and activities in connection with our services; and
• to facilitate contests, sweepstakes and similar promotions.

We may use automated systems and tools to assist with identity verification, compliance checks, fraud detection and preliminary eligibility assessments. These tools do not make final credit decisions.

The personal information we collect from you may also be used to detect, investigate and prevent fraudulent transactions or other illegal activities carried out in connection with the services we provide and to protect the rights and property of us and you.

If you do not provide some of your personal information, we may not be able to provide credit and other services to you.

We may disclose this information to the following types of entities, some of which may be located overseas:

• CRBs, including for a credit guarantee purpose;
• other persons who provide credit or other products to you, or to whom an application has been made by you for those products;
• any person or entity who represents you including financial consultants, accountants, lawyers, mortgage brokers, persons holding power of attorney, guardians and advisers;
• any industry body, government authority, tribunal, court or otherwise in connection with any complaint regarding our services;
• any investors, agents or advisers, trustees, ratings agency or businesses assisting us with funding for credit made available to you or any entity that has an interest in your finance;
• where we are authorised to do so by law, or at the direction of law enforcement agencies or regulators;
• any person where you have provided us consent to do so;
• any of our associates, related entities or contractors;
• other guarantors or borrowers (if more than one) or borrowers or prospective borrowers of any credit you guarantee or propose to guarantee;
• your referees, such as your employer, to verify the information you have provided;
• vendors, consultants and similar service providers who process your personal information on our behalf when they provide certain services to us, such as data analytics, research, marketing and financial services;
• any person considering acquiring an interest in our business or assets;
• any organisation providing online verification of your identity (including CRBs; we will notify you and obtain consent as required under the AML/CTF Act);
• any of our related businesses, authorised representatives and credit representatives.

Some service providers or related vendors who assist us (for example, cloud hosting, customer support, identity verification, data storage/backup, analytics, or document execution) are located outside Australia. We take reasonable steps (such as contractual safeguards, vendor assessments and controls) to ensure overseas recipients handle personal information in accordance with the Australian Privacy Principles.

We are likely to disclose limited personal information to recipients in India, the Philippines, and Fiji. (We also use Australian-based service providers; these are not 'overseas' recipients.) On request, we can provide a summary of key third-party service providers (and their country locations) used to deliver our services: [email protected].

Before disclosing personal information to overseas recipients, we take reasonable steps to ensure appropriate contractual and governance safeguards are in place to require those recipients to handle personal information in a manner consistent with the Australian Privacy Principles.

We collect, use and disclose your credit-related information in our interactions with CRBs. We collect, use and disclose this information to assess your credit worthiness and to manage any finance we provide to you.

If you fail to meet your repayment obligations for any financing arrangement with us, or otherwise commit a serious credit infringement, we may disclose this information to a CRB.

You have a right to request access to the credit-related information that we hold about you, and to request its correction.

You can contact the CRBs that we disclose your credit-related information to for any additional information by using the contact details below:

• Equifax Pty Ltd — equifax.com.au/contact
• Experian Australia Credit Services Pty Ltd — experian.com.au/contact-us
• illion Australia Pty Ltd — bankstatements.com.au/about/contact

If you believe you have been, or are likely to be, a victim of fraud, you may request that we do not use or disclose your credit-related information, in accordance with the Privacy Act and the Privacy (Credit Reporting) Code.

We will send you marketing messages if you have asked us to do so, if you have bought goods or services from us, or if you have provided us with your personal information when you entered a competition or registered for a promotion. We will ask for your consent before we share any of your personal information with a third party for their direct marketing purposes.

You can ask us to stop sending you marketing messages at any time by contacting us at [email protected].

We will not hold your personal information for any longer than is reasonably necessary for the specific purpose for which it was collected.

In some circumstances, we are required by law to retain personal information for minimum periods, including under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth). Where this applies, we retain information for the period required by law, even if our relationship with you has ended.

When we consider how long we will hold your personal information we will take into account the amount, nature and sensitivity of that information, the potential risk of harm from its unauthorised use or disclosure, why we need it and any applicable legal requirements that may require us to retain this information for a longer period.

You have a right to access your personal and credit-related information and to request its correction.

You may make a request to access or correct the personal and credit-related information we hold about you by contacting us on 1800 4634 6489 or contact the Compliance Manager via email at [email protected]. We aim to acknowledge requests promptly and respond within 30 days (or inform you if more time is required).

If you are unhappy with how we may have handled your personal or credit-related information, you can make a complaint by contacting us on 1800 4634 6489. We will acknowledge receipt of your complaint within 2 business days.

We will investigate your complaint and provide a response within 10 business days, provided that you have given us all information we consider is reasonably necessary and we have completed our investigation. If we need further information or more time to investigate your complaint, we will contact you directly and seek to agree an alternative period of time with you.

If you are dissatisfied with our response, you may make a complaint to the Australian Financial Complaints Authority (AFCA), which can be contacted on 1800 931 678 or [email protected]. You can also make a complaint directly to the OAIC Privacy Commissioner who can be contacted on either www.oaic.gov.au or 1300 363 992.

We collect information in relation to employees (and also our partners and contractors) as part of their application and onboarding processes and during the course of their relationship with us, either from them or in some cases from third parties such as recruitment agencies. This may include information about the person's health, their right to work in Australia, or other sensitive information. For some roles, our people may need to undergo vetting, such as background checking, security clearance or a criminal history search.

We may disclose personal information of our people to third parties in connection with vetting, and otherwise in connection with their relationship with us and their work. These third parties are usually in Australia but may be based overseas. When disclosing our people's information we ensure that the recipient is bound by an obligation of confidentiality, where it is lawful and appropriate to do so.

Under the privacy legislation, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.