If you are in a country that is a member of the European Economic Area (EEA), the EU General Data Protection Regulation 2016/679 (‘GDPR’) governs the way we collect, use, hold, process and disclose your personal information. Under the GDPR, we are a data controller. We make decisions on how and why your personal information is processed.
The types of information that we collect and hold about you could include:
We may collect information about you because we are required or authorised by law to collect it. There are laws which require us to collect personal information. For example, we require personal information to verify your identity under Australian Anti-Money Laundering law.
If you’re an internet customer of ours, we monitor your use of internet services to ensure we can verify you and can receive information from us, and to identify ways we can improve our services for you.
If you start but don’t submit an on-line application, we can contact you using any of the contact details you’ve supplied to offer help completing it. The information in applications will be kept temporarily then destroyed if the application is not completed.
We also know that some customers like to engage with us through social media channels. We may collect information about you when you interact with us through these channels. However, for all confidential matters, we’ll ensure we interact with you via a secure forum. To improve our services and products, we sometimes collect de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our web applications is secure.
Unless it’s unreasonable or impracticable, we will try to collect personal information directly from you (referred to as ‘solicited information’). For this reason, it’s important that you help us to do this and keep your contact details up-to-date.
There are a number of ways in which we may seek information from you. We might collect your information when you fill out a form with us, when you’ve given us a call or used our website. We also find using electronic means, such as email or SMS, a convenient way to communicate with you and to verify your details.
Sometimes, we will collect information about you from other sources as the Privacy Act 1988 permits. We will do this only if it’s reasonably necessary to do so, for example, where:
If you don’t provide your information to us, it may not be possible:
We will collect your credit information in the course of you answering the enquiries we make of you relating to the credit assistance you seek from us. In addition to what we say above about collecting information from other sources, other main sources for collecting credit information are:
Sometimes, people share information with us we haven’t sought out (referred to as ‘unsolicited information’). Where we receive unsolicited personal information about you, we will check whether that information is reasonably necessary for our functions or activities. If it is, we’ll handle this information the same way we do with other information we seek from you. If not, we’ll ensure we do the right thing and destroy or de-identify it.
However we’ll never ask you for your security details in this way – if you are ever unsure, just contact us
When we receive personal information from you directly, we’ll take reasonable steps to notify you how and why we collected your information, who we may disclose it to and outline how you can access it, seek correction of it or make a complaint.
Sometimes we collect your personal information from third parties. You may not be aware that we have done so. If we collect information that can be used to identify you, we will take reasonable steps to notify you of that collection.
We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:
We may store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.
We’ll only keep your information for as long as we require it for our purposes. We may be required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.
Collecting your personal information allows us to provide you with the products and services you’ve asked for. This means we can use your information to:
Can we use your information for marketing our products and services?
We may use or disclose your personal information to let you know about other products or services we or a third party make available and that may be of interest to you.
We will always let you know that you can opt out from receiving marketing offers. With your consent, we may disclose your personal information to third parties for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We won’t sell your personal information to any organisation.
Yes, You Can Opt-Out
You can let us know at any time if you no longer wish to receive direct marketing offers from us. We will process your request as soon as practicable.
We’ve just told you some of the main reasons why we collect your information, so here’s some more insight into the ways we use your personal information including:
What are the grounds which we will deal with your personal information under the GDPR?
Under the GDPR, we must have a legal ground in order to process your personal information. The legal grounds that we may rely on are:
We are required to keep some of your information for certain periods of time under law, such as the Corporations Act, the Anti-Money Laundering & Counter-Terrorism Financing Act, and the Financial Transaction Reports Act for example.
We are required to keep your information for 7 years from the closure of accounts, or otherwise as required for our business operations or by applicable laws.
We may need to retain certain personal information after we cease providing you with products or services to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and/or for proper record keeping.
To make sure we can meet your specific needs and for the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.
Sharing Your Information We may use and share your information with other organisations for any purpose described above.
Sharing with your representatives and referees
We may share your information with:
Sharing with third parties
We may share your information with third parties in relation to services we provide to you. Those third parties may include:
Sharing outside of Australia
We may use overseas organisations to help conduct our business. As a result, we may need to share some of your information (including credit information) with such organisations outside Australia. The countries in which those organisations are located are:
We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.
Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.
Where we transfer your information from the EEA’ to a recipient outside the EEA we will ensure that an adequate level of protection is in place to protect your personal information such as putting in place contractual protections to ensure the security of your information.
We‘ll always give you access to your personal information unless there are certain legal reasons why we can’t. You can ask us in writing to access your personal information that we hold. In some cases we may be able to deal with your request over the phone.
We will give you access to your information in the form you want it where it’s reasonable and practical. We may charge you a small fee to cover our costs when giving you access, but we’ll always check with you first.
We’re not always required to give you access to your personal information. Some of the situations where we don’t have to give you access include when:
If we can’t provide your information in the way you’ve requested, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.
Contact us if you think there is something wrong with the information we hold about you and we’ll try to correct it if it’s:
If you are worried that we have given incorrect information to others, you can ask us to tell them about the correction. We’ll try and help where we can - if we can’t, then we’ll let you know in writing.
If you ask us to correct credit information, we will help you with this in the following way.
Helping you manage corrections
Whether we made the mistake or someone else made it, we are required to help you ask for the information to be corrected. So we can do this, we might need to talk to others. However, the most efficient way for you to make a correction request is to send it to the organisation which made the mistake.
Where we correct information
If we’re able to correct the information, we’ll let you know within five business days of deciding to do this. We’ll also let the relevant third parties know as well as any others you tell us about. If there are any instances where we can’t do this, then we’ll let you know in writing.
Where we can’t correct information
If we’re unable to correct your information, we’ll explain why in writing within five business days of making this decision. If you have any concerns, you can access our external dispute resolution scheme or make a complaint to the Office of the Australian Information Commissioner.
Time frame for correcting information
If we agree to correct your information, we’ll do so within 30 days from when you asked us, or a longer period that’s been agreed by you.
If we can’t make corrections within a 30 day time frame or the agreed time frame, we must:
How do you make a complaint?
If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us.
You can contact us by using the details below:
Carl Matera – 0433224172 or firstname.lastname@example.org
We are committed to resolving your complaint and doing the right thing by our customers. Most complaints are resolved quickly, and you should hear from us within five business days.
Need more help?
If you still feel your issue hasn't been resolved to your satisfaction, then you can raise your concern with the Office of the Australian Information Commissioner:
If you are located in the EEA, you can contact the relevant data protection authority (for example in the place you reside or where you believe we breached your rights). For example, the Office of the UK Information Commissioner:
Office of the UK Information Commissioner
• Online: www.ico.gov.uk
• Phone: 0303 123 1113
• Live chat: https://ico.org.uk/global/contact-us/live-chat
If your complaint relates to how we handled your access and correction requests
You may take your complaint directly to our external dispute resolution scheme or the Office of the Australian Information Commissioner. You are not required to let us try to fix it first.
For all other complaints relating to credit information
If you make a complaint about things (other than an access request or correction request) in relation to your credit information, we will let you know how we will deal with it within seven days.
Ask for more time if we can’t fix things in 30 days
If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take. We will also ask you for an extension of time to fix the matter. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
Letting you know about our decision
We’ll let you know about our decision within 30 days or any longer agreed time frame. If you have any concerns, you may complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.
If you reside in the EEA, you can also:
You can contact us if you wish to exercise these rights. See ‘Contact Us’ for more information. If we refuse any request you make in relation to these rights, we will write to you to explain why and how you can make a complaint about our decision.
We care about your privacy. Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback.
You can contact us by using the details below:
Carl Matera – 0433224172 or email@example.com
If you have general enquiry type questions, you can choose to do this anonymously or use a pseudonym. We might not always be able to interact with you this way, however, as we are often governed by regulations that require us to know who we’re dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:
In certain circumstances we may be required to collect government-related identifiers such as your tax file number. We will not use or disclose this information unless we are authorised by law.
This Policy may change. We will let you know of any changes to this Policy by posting a notification on our website.
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