Privacy

The kinds of personal information which we will collect and hold

Collection

It is our usual practice to collect personal information directly from the subject individual or their authorised representative(s).

Personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether or not recorded in a material form, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Some examples of some personal information we might collect are:

1. name;

2. address;

3. contact details such as phone number, email address; and

4. date of birth.

Identification

You may choose to interact with us using a pseudonym and/or not identify yourself.

In circumstances where we are required to do so, or are authorised by law, a court or tribunal to ask for your identification, we will request your personal information.

Further it is likely that it will be impractical for us to interact with you without some form of identification, and therefore we will request identification details from you at the beginning of each transaction.

For example we will not be able to open a commercial credit trading account or process a commercial credit application for you without obtaining identification details.

How we will collect and hold your personal information

We only collect and hold personal information by lawful and fair means.

In some circumstances, we may collect and hold personal information that has been collected from a third party or publicly available source. This will likely occur in instances where:

1. you have consented for this collection (which would usually be via our privacy statement and/or credit application form); or

2. you would reasonably expect us to collect your personal information in this way and it is necessary for us to collect this information for a specific purpose (such as investigation of a complaint).

We will take steps to hold personal information in a manner which is secure and protected from

unauthorised access.

Your information may be held in either a physical form or in electronic form on our IT system.

We will take steps to protect the information against the modification, disclosure or misuse by including such things as physical restrictions, password protection for accessing electronic IT systems.

 

We will also endeavour to ensure that our service providers have protection for electronic IT systems and other necessary restrictions.

 

We will endeavour to ensure our staff are trained with respect to the security of the personal information we hold and we will restrict any access where necessary.

 

We will endeavour to destroy and de-identify the personal information once it is no longer required.

 

In the event we hold personal information that is unsolicited and we were not permitted to collect it, the personal information will be destroyed as soon as practicable.

 

If we collect personal information about you from someone else, we will advise you as soon as practicable that this information has been collected and the circumstances which surround the collection.

 

The purpose for which we collect and hold personal information

 

We will endeavour to only collect and hold personal information which is relevant to the operation of our company.

 

Our purpose for collecting or holding personal information about you is so that it may be used directly for our functions or activities.

 

We may use your personal information for the functions or activities of our company to:

1. assess credit applications;

2. review existing credit terms;

3. assess credit worthiness;

4. collect overdue payments;

5. assess credit guarantees (current and prospective);

6. internal management purposes;

7. marketing;

8. sales;

9. business development purposes and direct marketing.

10. customer service and support

 

We may also collect personal information (including sensitive information) for both the primary purposes specified herein and purposes other than the primary purposes, including the purpose of direct marketing.

 

We may also collect personal information from other credit providers, Credit Reporting Body (CRB) and any other third parties for the purposes of our functions and activities including, but not limited to, credit, sales, marketing, customer service and support, and administration.

 

The purpose for which use and disclosure personal information

 

We will endeavour to only use and disclose personal information for the primary purposes noted above in relation to the functions or activities of our company.

 

In addition we may also use and disclose personal information (including sensitive information) for both the primary purposes specified herein and purposes other than the primary purposes, including the purpose of direct marketing.

 

Unless one or more of the below scenarios has occurred, we will take necessary steps to prevent personal information from being given to government agencies or other organisations.

1. You have provided your consent.

2. You would reasonably expect that your information would be so disclosed.

3. We have informed you that that your personal information will be provided to a third party.

4. We are required by law to provide your personal information to a government agency or other organisation.

5. The disclosure of the information will prevent a serious threat to somebody’s life or health.

6. The disclosure of the information reasonably necessary for the enforcement of criminal law.

 

Further we will endeavour to only disclose personal information for the purpose in which it was collected, unless disclosure is reasonably necessary to:

1. assist in locating a missing person;

2. lessen or prevent a serious threat to life, health or safety;

3. take appropriate action with suspected unlawful activity or serious misconduct;

4. facilitate or assist with diplomatic or consular functions or activities;

5. assist certain defence force activities outside Australia;

6. establish or exercise a defined legal or equitable claim; or

7. facilitate or assist confidential alternative dispute resolution activities.

 

We will take steps not to disclose personal information for direct marketing purposes unless consent has been provided.

 

In any event you will be provided with an opt out option with respect to direct marketing should you wish to be excluded from direct marketing.

 

We will record this information on our opt out register.

 

We will endeavour not to use or disclose a government related identifier unless:

1. the use or disclosure of the identifier is reasonably necessary for us to verify your identity for the purposes of our activities or functions; or

2. the use or disclosure of the identifier is reasonably necessary for us to fulfil our obligations to an agency or a State or Territory authority; or

3. the use or disclosure of the identifier is required or authorised by or under an Australian law or a court/tribunal order; or

4. a permitted general situation (as that term is defined in the Act) exists in relation to the use or disclosure of the identifier; or

5. we reasonably believe that the use or disclosure of the identifier is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.