The kinds of personal information (including credit-related information) we collect, and the purposes for which we do that;

Transcription

1 At Flexigrup it is imprtant t us that we manage yur persnal infrmatin securely and cnsistently with relevant legislatin, including the Privacy Act 1988 (Cth) ( Privacy Act ) as well as the Credit Reprting Privacy Cde (where applicable). This Plicy utlines hw Flexigrup and its related cmpanies, including Flexirent Capital Pty Limited ACN ; Lmbard Finance Pty Limited ACN ; Once Credit Pty Limited ACN , Flexi Online Pty Limited ACN , Rent Smart Pty Limited ACN and Rent Smart Servicing Pty Limited ACN ( we / us ) cllect, disclse, use, stre r therwise handle persnal infrmatin. This Plicy explains: The kinds f persnal infrmatin (including credit-related infrmatin) we cllect, and the purpses fr which we d that; hw we manage the persnal infrmatin that we cllect abut yu; hw yu can seek access t and crrectin f that infrmatin; if necessary, hw yu can make a cmplaint relating t ur handling f that infrmatin. This plicy is nt limited t current custmers r guarantrs f custmers (where applicable) it relates t ther individuals wh deal with us, whether in relatin t the prvisin f credit r therwise. We will cllect certain infrmatin abut yu depending n the circumstances in which the prduct r service is being prvided. This infrmatin can include: key persnal infrmatin such as yur name, residential and business addresses, telephne numbers, and ther electrnic addresses, financial and related infrmatin, such as yur ccupatin, accunts, assets, expenses, incme, dependents, and regarding yur emplyment, financial and business dealings and ther relevant events; yur transactin histry (with us and ur assciates r relevant third parties). This infrmatin includes prducts yu may have used with us in the past, yur payment histry, and the capacity in which yu have dealt r deal with us; ther relevant infrmatin - depending n the circumstances this may als include health and medical infrmatin (eg if it is relevant t a hardship request), membership f prfessinal bdies, tax file number infrmatin (ther gvernment identifiers (eg if relevant t identifying yu).

2 In the event that we need t cllect infrmatin abut yu in relatin t credit matters, this can include: infrmatin such as accunt numbers r custmer identifier numbers; credit applicatin histry with us and ther credit prviders, such as the type f credit yu applied fr, the amunt f credit yu have applied fr, the start and end date f relevant credit; repayment histry infrmatin, such as and whether yu we any payments t us r anther credit prvider (regardless f the capacity in which that credit was prvided) that are verdue by 60 days; credit ratings, scres and evaluatins abut yu and yur credit wrthiness; Curt prceedings infrmatin abut yu. This is infrmatin abut a judgment f an Australian curt that is made against yu that relates t credit that was prvided t, r applied fr, by yu, such as whether yu have been declared bankrupt r have been subject t inslvency; whether we have accessed yur credit infrmatin previusly; default infrmatin abut yu. This is infrmatin abut a payment wed by yu as a brrwer r guarantr in cnnectin with cnsumer credit that remains verdue fr mre than 60 days and which we can disclse t a credit reprting bdy if certain requirements under the Privacy Act are met; payment infrmatin abut yu. Payment infrmatin is a statement that an verdue payment in relatin t which default infrmatin was prvided t a credit reprting bdy has been paid; new arrangement infrmatin abut yu. This is infrmatin abut yu having entered int certain types f arrangements with us in relatin t cnsumer credit where yu have been verdue in making a payment and we have prvided default infrmatin t a credit reprting bdy. New arrangement infrmatin is either that the terms f cnditins f that cnsumer credit have been varied as a result f yu being verdue r that yu have been prvided with new credit relating t the riginal amunt f credit; persnal inslvency infrmatin abut yu. This is infrmatin recrded in the Natinal Persnal Inslvency Index and relating t yur bankruptcy, a debt agreement prpsal given by yu, a debt agreement made by yu, a persnal inslvency agreement executed by yu, a directin given, r an rder made, under the Bankruptcy Act that relates t yur prperty r an authrity signed under the Bankruptcy Act that relates t yur prperty; publicly available infrmatin abut yu: that relates t yur activities in Australia r the external Territries and yur credit wrthiness; and that is nt curt prceedings infrmatin abut yu r infrmatin abut yu that is entered r recrded in the Natinal Persnal Inslvency Index; An pinin we have n reasnable grunds that yu have cmmitted a serius credit infringement in relatin t cnsumer credit that we have prvided t yu. A serius credit infringement includes, in summary: that yu were fraudulently btaining (r attempting t btain) cnsumer credit; r that yu are fraudulently evading (r attempting t evade) yur cnsumer credit bligatins; r that yu are n lnger intending t cmply with yur cnsumer credit bligatins we have nt been able t cntact yu fr 6 mnths in accrdance with the Privacy Act.

3 We set ut abve sme f the cnsumer credit infrmatin relating t individuals that we may cllect. The Privacy Act has certain specific rules abut tw types f cnsumer credit related infrmatin: credit infrmatin this infrmatin relates primarily t yur credit-related dealings with us and we can disclse this infrmatin t credit reprting bdies that reprt n cnsumer credit wrthiness ( CRBs ). credit eligibility infrmatin ( CEI ) this infrmatin is prvided t us by CRBs, s it may als include infrmatin abut yur credit related dealings with ther credit prviders. CEI als includes any credit wrthiness infrmatin that we derive frm the data frm a credit reprting bdy, fr example credit ratings, scres and evaluatins abut yu and yur credit wrthiness. The entities cvered by this Plicy d nt all cllect r hld CEI r credit infrmatin. Where we d cllect r hld these types f infrmatin, this Plicy als applies t it. In many circumstances, we will cllect the abve infrmatin primarily frm yu (r frm smene wh is representing r assisting yu). Hwever, there are certain instances in which we will cllect infrmatin abut yu frm third parties where it is unreasnable r impracticable t cllect it directly frm yu. Fr example, even where yur applicatin is fr cnsumer credit, we may cllect infrmatin abut yu frm a business which prvides infrmatin abut cmmercial credit wrthiness fr the purpse f assessing yur applicatin. Other third parties that we may cllect yur infrmatin frm include: ur agents; yur c-applicant (if any); yur emplyers, accuntant, referees, banks, landlrds, guarantrs, lawyers, financial advisers r thers with whm yu have previusly had dealings; ther FlexiGrup entities wh may have infrmatin abut yu; in relatin t credit infrmatin by cntacting relevant CRBs and ther credit prviders wh may have infrmatin abut yu relevant t us; in relatin t identificatin infrmatin by cntacting relevant CRBs and ther identificatin service prviders; by accessing infrmatin abut that is in the publicly available (eg internet surces r a search f white pages); card schemes; insurers (such as insurers wh prvide insurance in relatin t yur credit); yur executr, administratr r attrney; service prviders t us (including debt cllectin agencies, intrducers, private investigatrs, prfessinal advisers); prfessinal rganisatins; public and subscriber nly databases; any persn cnsidered necessary in ur view t execute yur instructins; and gvernment authrities.

4 We will hld yur persnal infrmatin in paper r ther physical frm, but it is usually held in electrnic frm n ur systems. Service prviders may hld the infrmatin fr us. Yur persnal infrmatin is prtected by varius physical, electrnic and prcedural safeguards. Where a service prvider hlds yur infrmatin, we require thse service prviders t adhere t ur apprved standards f security and cnfidentiality t ensure the cntinuing prtectin f yur persnal infrmatin. We train staff wh handle yur persnal infrmatin t ensure that yur persnal infrmatin is handled apprpriately. Our prcedures ensure that yur persnal infrmatin is nly made available t staff where necessary. Persnal infrmatin we cllect abut yu will nly be held, used and disclsed as is reasnably necessary fr ur business purpses and as permitted by law. Purpses fr which we will usually hld, use and disclse yur persnal infrmatin, depending n the circumstances and the nature and prducts and services yu are btaining frm us, include: in rder fr us t decide whether t prvide a prduct applied fr r service requested (this might include evaluating yur credit wrthiness, r deciding whether t accept yu as a guarantr); prviding the prducts r services that we prvide, including related arrangements (fr example, where we prvide yu with a credit t make a purchase, r where ur prduct is a payment service, that includes arranging fr the purchase t be paid fr r the payment t be made); managing the prducts and services the we prvide; the nging mnitring f credit wrthiness; t detect and prevent instances f fraud, unlawful cnduct, and ther risks t yu r ur prducts and services; t administer yur insurance plicy, assess any insurance risks r claims assciated with yu r ur prducts r services; dispute and cmplaint reslutin, and assisting ther credit prviders t d the same; enfrcing ur rights, including the cllectin f utstanding payments and where necessary, initiating legal prceedings undertaking review and maintenance f ur systems and infrastructure, undertaking research and develpment regarding ptential prducts and services; undertaking securitisatin activities and ther activities relating t funding and capital requirements; enabling ur assciated entities and selected ther entities t prmte their prducts and services t custmers; meeting any legal and regulatry requirements we are subject t, r may be impsed n us. marketing prducts and services prvided by us and ur related entities; develping an understanding f the prducts and services yu may be interested in receiving frm us and ur related entities; cmpiling statistical data e.g. credit scring infrmatin participating in the credit reprting system and prviding infrmatin t CRBs as permitted by Part IIIA f the Privacy Act and the Credit Reprting Cde; assisting custmers in meeting their credit related bligatins; enfrcing ur rights, including debt recvery and ther enfrcement; and

5 dealing with serius credit infringements, and assist ther credit prviders t d the same. cmplying with varius Australian laws which may specifically require us t cllect yur persnal infrmatin, and t ther laws where cllecting yur infrmatin is necessary in rder fr us t cmply with ur bligatins. Sme f the key laws which may apply include: the Natinal Cnsumer Credit Prtectin Act, the Anti-Mney Laundering and Cunter-Terrrism Financing Act, the Persnal Prperty Securities Act and State and Territry real prperty and security interests laws, the Financial Sectr (Cllectin f Data) Act, the Crpratins Act and ther regulatry legislatin, the Taxatin Administratin Act, the Incme Tax Assessment Act and ther taxatin laws, Where the Privacy Act permits it, we may disclse yur persnal infrmatin fr the purpses abve t third parties. Other third parties that we may disclse yur persnal infrmatin t include: yur c-applicant (if any) related entities based in Australia r verseas; entities that prvide services t us such as mailing huses r call centre peratrs; entities prviding ther services t us, including legal services, financial services, market research and data prviders; ur assignees r ptential assignees, r where we act as an agent fr, r therwise n behalf f, anther persn, t the principal r that ther persn; the supplier f any gds r services financed with credit we prvide; retailers, where the payment r credit service prvided by us invlves payments t the retailer fr gds r services t be prvided by them; ther financial institutins r entities such as banks and credit prviders; identificatin service prviders; insurers, assessrs, underwriters, brkers and ther distributrs; gvernment regulatry bdies in Australia and verseas; if apprpriate, guarantee r security prviders; rganisatins invlved in debt assignment r securitisatin arrangements; debt cllectrs r ther enfrcement bdies;

6 entities wh wish t be invlved in ur business, r acquire an interest in ur business; third parties yu authrise t act n yur behalf r that are therwise cnnected with yu (such as yur accuntant, legal representative r referee) and Law enfrcement agencies. Sme f these entities may nt be lcated in Australia, and may nt have an Australian link. Fr example, we emply service prviders in cuntries such as the Philippines. In additin, althugh many f the retailers we deal with are in Australia, sme f them are verseas. Therefre, when yu ask us t make a payment t r t prvide credit fr a prduct r service frm such a retailer, we will prvide infrmatin t that retailer and als t banks and ther financial institutins, wh may als be verseas, wh are invlved in prcessing that payment. These entities are nt ur service prviders, and we d nt cntrl hw they manage yur infrmatin Yur cnsumer credit infrmatin may als be disclsed, where relevant, in many f the circumstances described abve. In additin, where the Privacy Act permits it, we are permitted t disclse yur credit infrmatin t CRBs fr the purpses abve. CRBs may include the infrmatin we prvide t them in their reprts in rder fr them t cnduct an assessment f yur credit wrthiness. CRBs t whm we may disclse yur infrmatin include: Website: Phne: Address: Attentin: D&B Public Access Centre, PO Bx 7405, St Kilda, VIC 3004 Website: Phne: Address: Equifax, PO Bx 964, NORTH SYDNEY, NSW 2059 Yu are entitled t: pt ut f direct marketing pre screenings: CRBs ften use credit infrmatin t assist credit prviders t market their prducts and services. If yu d nt want a credit reprting bdy t use yur credit infrmatin in this manner, the Privacy Act gives yu the right t request yu be excluded frm being cntacted;

7 request nn-disclsure where yu believe yu have been, r are likely, a victim f fraud: if yu believe that yu are a victim f fraud, r are likely t be a victim f fraud, then yu are entitled, under the Privacy Act, t request that a credit reprting bdy nt use r disclse any f yur credit infrmatin. Yu have specific rights under Australian law in relatin t requesting access t and crrectin f persnal infrmatin we hld abut yu and making a privacy cmplaint. Yu can request access t the persnal infrmatin we hld abut yu subject t certain exceptins under the Privacy Act. Yu are entitled t specify hw yu wish t access yur persnal infrmatin, s lng as this is reasnable and practicable. In rder t access yur persnal infrmatin, please cntact the Privacy Officer n Given that the infrmatin we will have is f a sensitive nature, we will need t verify the identity f anyne requesting access t yur persnal infrmatin, s as t ensure that we d nt prvide that infrmatin t a persn r peple wh d nt have the right t access that infrmatin. We ask that yur request fr infrmatin be as specific as pssible s that we can accmmdate yur request. We will usually prvide yu with access within 30 days f a request but in sme circumstances it may take lnger. Please nte, that under Australian law, FlexiGrup is entitled t refuse yu access t yur infrmatin in the fllwing circumstances: access wuld be unlawful; denying access is required r authrised by r under an Australian law r a curt/tribunal rder; r access wuld prejudice enfrcement activities r the taking f apprpriate actin in relatin t unlawful activity r serius miscnduct. There may be ther reasns fr FlexiGrup refusing t prvide yu access t yur infrmatin. We take every stp that is reasnably practicable t ensure that the persnal infrmatin we cllect, use and disclse is accurate, cmplete and up-t-date. The Privacy Act gives yu the right t request crrectin f the persnal infrmatin we hld if yu believe that the persnal infrmatin we have is incrrect, then please cntact FlexiGrup n , r fax us n (02) r us at servicerecvery@flexigrup.cm.au. In the event that we d nt agree t yur request fr crrectin, we will give yu ntice f this utlining ur reasns and what next steps yu can take. Yu may als request us t assciate a statement with that infrmatin t the effect that the infrmatin is inaccurate, ut-f-date, incmplete, irrelevant r misleading s that it is apparent t users f the infrmatin.

8 The Privacy Act gives yu the right make a cmplaint if yu believe that we have nt cmplied with its bligatins under the Privacy Act, including bligatins relating t cnsumer credit infrmatin under Part IIIA f the Privacy Act and the Credit Reprting Cde. If yu believe this t be the case, please cntact FlexiGrup n , r fax us n (02) r us at servicerecvery@flexigrup.cm.au. We will endeavur t cntact yu within 7 days f yu making yur cmplaint acknwledging receipt f yur cmplaint. It is ur plicy t investigate and reslve all cmplaints (where practicable) within 30 days f receiving the cmplaint. Where it is a legal requirement t d s, then in the event we need mre time t investigate and reslve yur cmplaint, we will ntify yu as t the reasns why and seek yur agreement t extend this 30 day perid (if yu d nt agree, we may then nt be able t reslve yur cmplaint). Please nte, that where yur cmplaint relates t yur credit infrmatin, we may cnsult with a credit reprting bdy r ther credit prvider in rder t investigate and reslve yur cmplaint. Depending n the type f cmplaint, it may als be necessary fr us t cnsult with ther third parties. In the event yur cmplaint is nt handled satisfactrily by us, yu can cntact the belw mentined External Dispute Reslutin Schemes ( EDR Scheme ) as set ut belw:- The apprpriate EDR scheme fr Flexirent Capital Pty Limited, Flexi Online Pty Limited, Once Credit Pty Limited and Lmbard Finance Pty Limited is Credit and Investments Ombudsman Limited (CIO) Website: Phne: Address: Credit and Investments Ombudsman, Reply Paid 252, Suth Sydney, NSW 1234 If yu wish t find ut mre infrmatin, r raise any specific r general cncerns, abut us and ur Privacy Plicy and privacy practices, the cntact details are as fllws: servicerecvery@flexigrup.cm.au Telephne: Fax: (02)