The term “you”, “your” and “user” refers to you as our client. If you are our client, additional information about our handling of your personal information may apply, for example under a privacy declaration or terms and conditions applicable to the product or service you obtain from us.
We are committed to respecting the privacy and protecting the personal information of our users and clients.
We are bound by privacy principles under the Privacy Act (1988) (Cth) which are applicable to private sector organisations, and other laws which govern the handling of personal information. We sometimes handle personal information relying on exemptions under these laws, for example in relation to employee records.
1. Information collection and use
We may collect various types of information from you. Some of this information is personal information, some is non-personal.
We may collect personal information (being information about you from which your identity is apparent or can reasonably be determined) for purposes including:
(a) identifying you and investigating and protecting against fraud and unlawful activity;
(b) complying with laws which apply to us (including counter-terrorism financing and anti-money laundering laws), assisting regulatory authorities and protecting our lawful interests;
(c) arranging and/or providing financial products and services for you, including assessing applications for finance;
(d) establishing, managing, administering, evaluating and improving our products or services including security and risk management, service development, research and planning;
(e) in relation to providing credit: credit scoring, securitisation and portfolio analysis;
(f) responding to your queries;
(g) subject to our legal obligations and your requests to opt-out, to provide you with promotional information about financial and investment products and services on an ongoing basis, by any means including telephone, email and other electronic messages (we may also share your personal information with our related bodies corporate and partners for this purpose).
We may not be able to do these things without your personal information. For example, we may not be able to provide you with our services or respond to your queries.
The types of personal information collected may include your name, address, postal or email details, financial details, credit-related personal information (see section 5 below) and other information that we may consider necessary.
Where reasonable and practicable to do so, we will generally collect your personal information directly from you. Collection can occur in a number of ways, including when you apply for or request information in relation to a product or service, including where you do so over the telephone or by e-mail. Personal information may also be collected during the course of our business relationship with you for example through your use of our services. We may record your interactions with us, including your telephone conversations with us and your use of our emails.
Occasionally we may collect personal information about you from other sources including public sources, information brokers and third parties such as those described in the ‘Disclosure of personal information’ section below. For example, in the course of assessing your application for a loan, we may collect such information from a credit reporting agency or financier, or from your employer or your landlord. Some of the personal information we collect from you is collected to meet our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).
2. Disclosure of personal information
Depending on the circumstances, we may disclose your personal information to our agents and service providers including providers of account management, application processing, archival, auditing, debt collection, banking, insurance, valuation, mailhouse services, technology and data processing services; government bodies including courts and tribunals; your executor, administrator, trustee, guardian or attorney; and your agents, such as financial or legal advisers. We may also disclose personal information to other entities within the Wingate group of companies, for any of the purposes for which we may collect, use or disclose information that is set out in this policy.
We may also disclose such information as required or permitted by any law, for example in response to a subpoena or to the Australian Taxation Office, following a direction issued under taxation laws.
Some of the third parties to whom we may disclose personal information may be located in other countries. We will comply with our obligations under the Privacy Act in relation to these disclosures.
3. Accessing and correcting your personal information
To make a request to access or correct any personal information we hold about you, please contact us as set out below. We may need to verify your identity. Please provide as much detail as you can about the particular information you seek, in order to help us locate it.
We will provide our reasons if we deny any request for access to or correction of personal information. Where we decide not to make a requested correction to your personal information, and you disagree, you may ask us to make a note of your requested correction with the information.
4. Information security
We take care to protect your personal information and employ a range of technical and administrative procedures to protect such information from unauthorised disclosure or loss. We keep personal information in physical and electronic records, both at our own premises and with the assistance of our service providers.
If you are considering sending us any personal information through electronic means, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard HTTP).
5. Credit reporting
We may collect, hold, use and disclose certain credit-related personal information about you including:
- permitted identification information e.g. names, date of birth, sex, 3 most recent addresses, employer and driver’s licence number;
- your applications for credit – the fact that you have applied for credit and the amount and type of credit;
- the identity of your current and previous credit providers;
- records of previous requests made by credit providers to credit reporting bodies (“CRBs”) for information about you in connection with consumer or commercial credit applications, guarantees and securitisation arrangements;
- information about defaults (where repayments are more than 60 days overdue, in certain circumstances);
- where those default repayments are no longer overdue, or new payment arrangements have been agreed;
- a credit provider’s opinion that you have committed a serious credit infringement (that is, acted fraudulently or shown an intention not to comply with your credit obligations);
- the start and end dates, credit limits and certain terms and conditions of your credit arrangements;
- information about court judgments against you;
- publicly available information relevant to your credit worthiness;
- certain insolvency information from the National Personal Insolvency Index;
- information derived by CRBs from the above information (e.g. assessments and ratings in respect of your credit worthiness); and
- information we derive from the above information (e.g. our own assessments and ratings in respect of your credit worthiness), (“credit-related personal information”).
This information may include information about your arrangements with other credit providers as well as with us. We may disclose some of these types of information to CRBs. CRBs may use credit-related personal information to maintain records on individuals which they may share with other credit providers for those providers’ own credit assessments.
The CRBs we may use include:
- Veda, PO Box 964 North Sydney 2059, www.mycreditfile.com.au, 1300 762 207
- Dun & Bradstreet, Level 7, 479 St. Kilda Road Melbourne 3004, www.dnb.com.au, [email protected], 1300 734 806
- Experian, GPO Box 1969, North Sydney NSW 2060, www.experian.com.au, 1300 784 134
- Tasmanian Collection Service, 29 Argyle Street, Hobart, www.tascol.com.au, [email protected], (03) 6213 5555
- You can contact those CRBs or visit their websites to see their policies on the management of credit-related personal information, including details of how to access your credit-related personal information they hold. You have the right to request CRBs not to:
- use or disclose your credit-related personal information, if you have been or are likely to be a victim of fraud; and
- use your credit-related personal information to determine your eligibility to receive direct marketing from credit providers.
In the event that any part of our business or its assets is ever sold, acquired, merged, liquidated, reorganised or otherwise transferred, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained therein to a third party acquiring the assets. While any transaction of this sort is being considered, we may also make limited relevant personal information available to prospective purchasers and legal and financial advisors and other relevant parties on a confidential basis.
7. Changes to this policy
We reserve the right to make changes to this policy. Such changes will be posted on this website and we will publish the effective date when the statement is updated.
If you have bookmarked this policy (or the Website) you will need to ensure that the bookmarked version has been updated so that you are aware of the most recent version of this policy.
Last update: July 2014