This Policy includes our credit reporting policy, that is, it covers additional information on how we manage your personal information collected in connection with a credit application. We refer to this type of personal information below as credit-related information.
If you are a body corporate, while we generally will deal with information in a similar manner to the way we deal with personal information (including credit related information) of an individaul, we are not obliged to and will not be bound to deal with your information in this way under applicable legislation and will not accept any liability if we fail to deal with information in this way.
1. Our commitment to protect your privacy
We understand how important it is to protect your personal information. This document sets out our commitment in respect of personal information we hold about you and what we do with that information.
Any personal information we collect about you will only be used for the purposes we have collected it for or as allowed under applicable law, including the Privacy Act 1988 (Cth) (the Privacy Act).
Where applicable, we abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and comply with the Credit Reporting Code made under that Act (credit reporting code).
2. Why we collect your Personal Information
We collect personal information from you for the purposes of dealing with you and in assisting us to arrange for the products and services you request to be provided to you. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. This may also entail collecting credit information where you decide to apply for credit.
3. What Information may we collect?
The type of information that we collect from you will depend on which products and services you choose to enquire about.
We may collect personal information (which includes credit information), credit elibigility information and with your consent, sensitive information. The meaning of these expressions is explained below.
Personal Information means information from which your identity is reasonably apparent and includes, Credit Information and Credit Eligibility Information. Examples are:
- identifying information, like your name, address and other contact details and your date of birth;
- information about your financial position, like your income, expenses, savings and assets and any (other) credit arrangements;
- your employment details;
- your tax file number;
- your reasons and objectives for applying for a product or service and where required other details such as the ages and number of your dependants and cohabitants, the length of time at your current address;
and other information we consider relevant to assessment of your application and in the case of an application for credit for submission to a lender.
Credit Information includes:
- details of credit applied for and details of the type and amount of credit granted;
- the fact that credit provided to you has been repaid;
- whether or not you have made payments on time;
- default information, being payments overdue for at least 60 days and for which collection action has started;
- information about your credit worthiness.
- details of any new arrangements made with you;
- court proceedings and person insolvency information, and
- if applicable, our opinion that you have committed a serious credit infringement
Credit Eligibility Information refers to Credit Information received by us from a Credit Reporting Body and includes Credit Reporting Information.
Credit-Related Information means Credit Information and Credit Eligibility Information.
Credit Reporting Body refers to an agency that holds credit information relating to individuals and businesses.
Credit-Reporting Information means Credit Information provided by a credit reporting body.
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 records.
4. How do we collect your Personal Information?
Where possible we will collect your personal information directly from you, but may also collect it from Credit Reporting Bodies and other people such as your creditors, financial institutions, other persons with whom you have dealings, referees, employers, landlords, accountants, lawyers, financial advisors and financial counsellors.
5. How do we use your Personal Information?
We may use your personal information (including Credit-Related Information) for the purposes of considering any application made by you for products or services offered by us, including credit, providing you with products and services, managing our relationship with you and running our business. We may also use your personal information for other purposes where required or permitted by law.
6. Use of your Personal Information for Direct Marketing Purposes
We may also use personal information for direct marketing and in order to tell you about other products and services offered by us or by our business partners and we may also provide your details to other organisations for specific marketing purposes.
We will consider that you consent to this use, unless you indicate to us that you opt out. You may opt out at any time if you no longer wish to receive marketing information or do not wish to receive marketing information through a particular channel, like email. In order to do so, you will need to request that we no longer send marketing materials to you or disclose your information to other organisations for marketing purposes and may contact us by telephoning us on 1300 661 991 or by writing to us at PO Box 6840, GCMC QLD 9726. If the direct marketing is by email you may also use the unsubscribe function in the email you receive. If the direct marketing is by SMS, you may reply "stop" and we will remove you from this list.
7. Personal Information about Third Parties
When you make application for credit we will ask you to provide us with personal information about other persons, such as referees and family members who we may contact. These persons are referred to as "Third Parties". When you provide this information to us you warrant that you are authorised to do so.
8. Contacting Third Parties and use of Social Media
We may, at any time while we are a credit provider to you, contact Third Parties to assist us in helping you honour your contractual obligations under any credit contract you have with us.
You also authorise us to use social media to contact you.
In circumstances where you have failed to honour your obligations to us and we are unable, for whatever reason, to contact you by other means, after making reasonable efforts to do so, you authorise us to make contact with persons listed by you as your contacts, connections and friends on social media sites where you are a user, so we can establish contact with you for the purpose of assisting you to make sure you honour your contractual obligations to us.
9. Do we disclose your Personal Information?
We may disclose your personal information to persons including:
- prospective lenders
- corporations which are related to us;
- a Credit Reporting Body;
- external service providers to us, such as organisations which we use to verify your identity, payment systems operators, mailing houses and research consultants;
- mortgage insurers, where lenders mortgage insurance is organised in respect to your credit;
- insurers and re-insurers, where insurance is provided in connection with our services to you;
- any industry body, tribunal, or court or otherwise in connection with any complaint regarding the services we provide to you;
- our professional advisors, such as accountants, lawyers and auditors;
- other credit providers and their professional advisors;
- your employer;
- the vendor of any goods you intend to purchase using any credit applied for;
- your representative, where authorised by you; or
- government and regulatory authorities, if required or authorised by law
We also exchange your personal information with others for the purposes of assisting you to make application for credit.
10. Current Members of the Safe Group of Companies
As indicated above, we may disclose your personal information to organisations which are a part of the Safe Group of Companiesto assist us, and them, in providing the products or services you request. Organisations which are currently members of the Safe Group of Companies include Safe Finance Pty Ltd (ACN 098 751 930), Safe Business Finance Pty Ltd (ACN 131 891 015), Safe Debt Management Pty Ltd (ACN 010 183 294), Safe Financial Group Pty Ltd (ACN 138 086 852) and Eastcoast Capital Pty Ltd (ACN 100 148 623) (the "Safe Group of Companies").
11. Security of your Personal Information and Disclosures Overseas
We take reasonable steps to ensure that your personal information held by us is protected from misuse, interference and loss, and from unauthorised access, disclosure or modification.
We may disclose your personal information to persons engaged by us to provide us with services. We will always seek protective measures to ensure our service providers take appropriate steps to protect that information in compliance with the Australian Privacy Principles and to restrict the use to which they can put that information.
In addition, where you previously lived in New Zealand and in circumstances where you have made an application for credit, we may seek a Credit Report about you from a New Zealand Credit Reporting Body, most likely Equifax New Zealand, and in doing so will disclose
12. Credit Reporting Bodies
A Credit Reporting Body collects Credit Information about individuals, which is then provided as a report to credit providers and others in the credit industry to assist credit providers in managing credit risk, collecting debts and other activities.
If you apply for credit or for credit assistance or apply to be a guarantor, we generally will apply for a credit report from a Credit Reporting Body and they will disclose to us, our related corporations and authorised agents, personal information about your credit worthiness. Personal information obtained by us from a Credit Reporting Body will be used by us to assess any application for credit and for other permitted purposes.
We may also disclose personal information about you to a Credit Reporting Body, including repayment history information, credit liability information and that you are in defualt under a credit arrangement or have committed a serious credit infringement if that is the case. A Credit Reporting Body may then include that information in reports it produces to other credit providers.
The Credit Reporting Bodies with whom we deal are:
We may seek and use commercial Credit Information about you to assess an application for consumer credit or commercial credit and seek and use consumer Credit Information about you to assess an application for commercial credit or consumer credit.
13. Credit pre-screening
Credit reporting bodies offer a service to credit providers wishing to send direct marketing material about credit services to individuals. This is called "credit pre-screening." You have the right to request that the credit reporting bodies do not use your information for this purpose. To opt out of credit pre-screening, contact the credit reporting body, using the contact details on their websites noted above.
14. Notifiable matters
In circumstances where you have made an application for consumer credit, we are required, under the credit reporting code, to ensure that you are aware of certain specific matters, namely:
- A credit reporting body may include credit information in reports provided to us to assist us to assess your credit worthiness;
- If you fail to meet your payment obligations in relation to consumer credit or commit a serious credit infringment, we may be entitled under the Privacy Act to disclose this to a credit reporting body. Any such report by us may affect your ability in the future to be able to obtain further credit;
- You have a right to access your personal information held by us and to request that we correct the information and also have a right to make a complaint to us. See other sections of this Policy for further details.
- Each credit reporting body offers a service to credit providers wishing to send direct marketing material about credit services to individuals. This is called "credit pre-screening." You have the right to request that a credit reporting body does not use your information for this purpose. To opt out of credit pre-screening, contact the credit reporting body, using the contact details on their websites noted above, and
- You also have a right to ask a credit reporting body not to use or disclose your personal information for a period if you believe on reasonable grounds that you have been or are likely to be a victim of fraud.
15. Updating your Personal Information
We take reasonable steps to make sure that the personal information that we collect, use or disclose is accurate, complete and up to date. It is important to us that personal information we hold about you is accurate and up to date. If you wish to make any changes to your personal information, please contact us.
16. Access and correction to your Personal Information and Credit Information
We will provide you with access to the personal information we hold about you on request. We may charge a fee for our costs of retrieving and supplying the information to you.
Depending on the type of request you make we may respond to your request immediately. Otherwise, we will endeavour to 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 personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.
If you are an individual, an explanation will be provided to you if we deny you access to the personal information we hold about you.
You can gain access to the information held about you by contacting our Privacy Officer, whose contact details are:
Address: PO Box 6840, GCMC, QLD 9726 Telephone: 1300 661 991 Email: email@example.com (marked for the attention of the Privacy Officer)
You can also request our Privacy Officer arrange to correct any personal information we hold about you which you believe is incorrect.
17. Notifiable Data Breaches
From February 2018, the Privacy Act includes a new Notifiable Data Breaches (NDB) scheme which requires us to notify you and the Office of the Australian Information Commissioner (OAIC) of certain data breaches and recommend steps you can take to limit the impacts of a breach (for example, a password change).
The NDB scheme requires us to notify about a data breach that is likely to result in serious harm to affected individuals. There are exceptions where notification is not requried. For example, where we have already taken appropriate remedial action that removes the risk of serious harm to individuals.
If we believe there has been a data breach that impacts your personal information and creates a likely risk of serious harm, we will notify you and the OAIC as soon as practicable and keep in close contact with you about the nature of the breach, the steps we are taking and what you can do to reduce the impacts to your privacy.
If you believe that any personal information we hold about you has been impacted by a data breach, you can contact us using the contact details above.
18. Privacy and our Website
When you deal with us via our website we collect additional personal information about you.
(a) Public Pages
Anytime you access an unsecured part of our website, that is, a public page which does not require you to log on, we will collect information about your visit, such as:
- the time and date of the visit;
- any information or documentation that you download;
- your browser type; and
- internet protocol details of the device used to access the site
You may change the settings on your browser to reject cookies, however doing so might prevent you from accessing the secured pages of our website.
When we receive emails, we will retain the content of the email and our response to you where we consider it necessary to do so.
We may add your email address to our mailing lists.
(d) Third Party Websites
20. Complaints and Questions
Once a question or complaint has been lodged, our Privacy Officer will respond to you as soon as possible. We will aim to deal with any complaints at the source of your complaint.
If you are not satisfied with the response you receive, please let us know. We will investigate further and respond to you.
If you are still not satisfied, you can contact external bodies that deal with privacy complaints. The Australian Financial Complaints Authority is our external dispute resolution scheme provider or the Federal Privacy Commissioner. Either of these bodies may forward your complaint to another external dispute resolution body if it considers the complaint would be better handled by that other body.
Australian Financial Complaints Authority
Post: GPO 3, Melbourne VIC 3001
Phone: 1800 931 678
Federal Privacy Commissioner
Post: GPO Box 5218 Sydney NSW 2001
Phone: 1300 363 992
Our Privacy Officer's contact details are:
Address: PO Box 6840, GCMC QLD 9726
Telephone: 1300 661 991
Email: firstname.lastname@example.org (mark for the attention of the Privacy Officer)