Purpose

We Easylink Finance Australia Pty LimitedABN 94143 298588 respect and are committed to protection of your personal information obtained from you or from a third party and held by us in the ordinary course of our business. The purpose of this Policy is to document and disclose our policy as regards the collection, dealing and protection of your personal information in accordance with the Australian Privacy Principles (“APPs”) which are contained in the Privacy Act 1988 (“Privacy Act”).

Personal Information

The term ‘personal information’ used in this Policy has the meaning given to it by the Privacy Act. It is the information and opinion about you. The type of information that we may collect and hold include:

• ID information such as your name, postal or email address, telephone numbers, and date of birth;
• other contact details such as social media handles;
• financial details such as your tax file number;
• health information;
• credit information such as details relating to credit history, credit capacity, and eligibility for credit (‘credit worthiness’); and
• other information we think is necessary.

Credit Information

We may check your credit worthiness on collection of your information from credit reporting bodies. We may also provide information to the credit reporting bodies in the ordinary course of our business. This information can include:

ID information:  a record of your name(s) (including an alias or previous name), date of birth, gender, current or last known address and previous two addresses, name of current or last known employer and drivers licence number.

Information request:  a record of a credit provider asking a credit reporting body for your information in relation to credit application, including the type and amount of credit applied for.

Default information:  a record of your consumer credit payments being overdue, that is payments regarding credit intended to be used wholly or primarily for personal, family or household purposes or to acquire, maintain, renovate or improve residential property for investment purposes or to refinance credit for any of these purposes.

Serious credit infringement:  a record of instance(s) when a credit provider reasonably believes that there has been a fraud relating to your consumer credit or that you have avoided paying your consumer credit payments and the credit provider can’t find you.

Personal insolvency information:  a record relating to your bankruptcy or your entry into a debt agreement or personal insolvency agreement.

Court proceedings information:  any court judgment relating to your credit.

Publicly available information:  a record relating to your activities in Australia and your credit worthiness.

Consumer credit liability information:  certain details relating to your consumer credit, such as the name of the credit provider, whether the credit provider has an Australian Credit Licence, the type of consumer credit, the day on which the consumer credit was entered into and terminated, the maximum amount of credit available and certain repayment terms and conditions.

Repayment history information:  a record of whether or not you’ve made monthly consumer credit payments and when they were paid.

Payment information:  If a credit provider gave a credit reporting body default information about you and the overdue amount is paid, a statement that the payment has been made.

New arrangement information:  If a lender gave a credit reporting body default information about you and your consumer credit contract is varied or replaced, a statement about this.

Sensitive information

Sensitive information has the meaning given to it by the Privacy Act. It is an information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record, health information, genetic or biometric information.

We do not collect sensitive information in the ordinary course of our business. If we do collect sensitive information in compliance with requirement of any law and which is reasonably necessary for the operation of our business functions or activities, we will obtain your consent to do so.

Collection required by Law

We collect information about you because we are required or authorised by law to collect it. There are laws that apply to us, including company and tax law, which require us to collect personal information. For example, we require personal information to verify your identity under Commonwealth Anti-Money Laundering law.

Online Activity

If you are dealing with us online, we monitor your online dealing to ensure we can verify you, you receive information from us and we identify ways to improve our services for you.

If you start but don’t complete or submit an online application, we can contact you using any of the contact details you’ve supplied to offer help completing and submitting it. The information in applications will be kept temporarily then destroyed if the application is not completed.

To improve our services and products, we may collect de-identified information from web users. That information could include IP addresses or geographical information to ensure your use of our services is secure.

How is personal information collected and held

We collect your information when you fill out a form with us, when you’ve given us a call, used our websites or attendedour office(s).Unless it’s unreasonable or impracticable, we try to collect personal information directly from you.It’s essential that you keep your contact details with us up-to-date.

We may collect information about you from other sources, in instances including where:

• we can’t contact you and we rely on publicly available information to update your contact details;and
• wedeal with your legal or financial advisers or other representatives.

The other main sources for collecting your information include:

• credit reporting bodies;
• your bank(s); and
• bodies that issue identification documents to help us check your identity.

Your information is securely stored by us in ways including paper and / or electronic form. 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:

• confidentiality requirements of our employees;
• document storage security policies;
• security measures for access to our systems;
• only giving access to personal information to a person who is verified to be able to receive that information;
• control of access to our buildings; and
• electronic security systems on our websites.

We can store your 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.

Consequences of not providing your Personal Information

If you don’t provide your personal information to us, we may not be able to:

• provide, manage or administer the service you want; or
• verify your identity or protect against fraud.

Unsolicited Personal Information

In the course of our business and while collecting your information from others, we may receiveyour personal information which we haven’t sought. For such unsolicited personal information, we will check whether that information is reasonably necessary for our business or for providing services to you. 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 destroy or de-identify it.

Notifying You

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.

If we collect information from third parties that can be used to identify you, we will take reasonable steps to notify you of that collection.

Retaining Information

We’ll only keep your information for as long as we require it for our purposes.  We’re also required to keep some of your information for particular time period under law, such as the Corporations Act, the Anti-Money Laundering & Counter-Terrorism Financing Act, and the Financial Transaction Reports Act for example.  When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.

Usage of Personal Information

Your personal information allows us to provide you the services sought by you. We can use your information:

• to identify or verify you or your authority to act on behalf of our customer;
• to assist in our arrangements with other organisations in relation to our services to you;
• to run our business and perform administrative and operational tasks, such as training staff, provide you information about our services, consider your request for services and process your application;
• to risk management;
• to develop and test systems, including our website and other online channels;
• to undertake planning, research and statistical analysis;
• to prevent or investigate any fraud or crime, or any suspected fraud or crime;
• as required by law, regulation or codes binding us; and
• for any purpose for which you have given your consent.

With your consent, we may disclose your personal information to third parties such as brokers or agents, or 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.

Sharing your Personal Information

We may share your information with other organisations for any purposes for which we use your information.

At your request

We may need to share your personal information with your representative or any person acting on your behalf (for example, financial advisers, lawyers, settlement agents, accountants, executors, administrators, trustees, guardians, brokers or auditors) andyour referee such as your employer (to confirm details about you).

With third parties

With your consent, we may disclose your personal information to third parties including:

• agents or referrers who refer your application or business to us;
• financial institutions, such as banks;
• organisations involved in debt collecting, including purchasers of debt;
• fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);
• organisations involved in surveying or registering a security property or which otherwise have an interest in such property;
• government or regulatory bodies (including APRA, ASIC and the Australian Tax Office) as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities);
• our accountants, auditors or lawyers and other external advisers;
• organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;
• organisations that participate with us in payments systems including merchants and  payment organisations; and
• other organisations involved in our normal business practices, including our agents and contractors.

Overseas Disclosures

With your consent we may share some of your information with organisations outside Australia in the course of our business.

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 such disclosure.

Accessing your Personal Information

Subject to certain formalities, you can access your personal information held by us unless certain legal reasons prevent such access.  You can ask us to access your personal information that we hold by filling out the Personal Information Access Form.  In some cases we may be able to deal with your request over the phone or in a branch.  You can contact us if you would like a copy of the form to be sent out to you.

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 reasonable costs when giving you access.

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:

• we believe there is a threat to life or public safety;
• there is an unreasonable impact on other individuals;
• the request is frivolous;
• the information wouldn’t be ordinarily accessible because of legal proceedings;
• it would prejudice negotiations with you;
• it would be unlawful;
• it would jeopardise taking action against serious misconduct by you;
• it would be likely to harm the activities of an enforcement body (e.g. the police); or
• it would harm the confidentiality of our commercial information.

We will inform you in writing 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.

Correcting your Personal and Credit Information

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:

• inaccurate;
• out of date;
• incomplete;
• irrelevant; or
• misleading.

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.

Since we will, if required, collect your credit information from third parties, we are not responsible for the incorrect information and will be unable to correct such information. The most efficient way for you to make a correction request is to send it to the organisation which made the mistake.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 will:

• let you know about the delay, the reasons for it and when we expect to resolve the matter;
• ask you to agree in writing to give us more time; and
• let you know you can complain to our external dispute resolution scheme or the Office of the Australian Information Commissioner.

Resolving your Privacy Issues

If you have a complaint about how we handle your personal information, you are always welcome to contact us by calling our office on 1300 851 802 or speaking to us In Person at our office. You could also provide your complaint in writing by post, email or personal delivery.

We are committed to resolving your complaint and doing the right thing. Most complaints are resolved quickly, and you should hear from us within five business days.

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:

Online:             www.oaic.gov.au/privacy

Phone:             1300 363 992

Email:              enquiries@oaic.gov.au

Fax:                 +61 2 9284 9666

Mail:                GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601

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.

If your complaint is in relation to your credit information, we will let you know how we will deal with it within seven days.

Extension of time

If we can’t fix things within 30 days, we’ll let you know why and how long we think it will take in resolving your complaint. 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.

Notifying the 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.

Contact us

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:

• post at the address; Level 2, Suite 221, 4Columbia Court, Baulkham Hills NSW, 2153.
• email at:  info@easylinkfinance.com.au
• calling our office on 02-9894 6944
• speaking to us in person at our office

Anonymous/Pseudonym

For general enquiries you can choose to contact us anonymously or use a pseudonym. However, we might not always be able to interact with you this way as we are often governed by strict regulations that require us to clear identity of the person we are dealing with. In general, we won’t be able to deal with you anonymously or where you are using a pseudonym when:

• it is impracticable; or
• we are required or authorised by law or a court/tribunal order to deal with you personally.

Government Related Identifiers

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.

Changes to Privacy Policy

We may change and update this Policy from time to time. Whenever the policy is changed, a notification of change of policy and the changed policy will be posted on our website.  Any information collected after an amended privacy statement has been posted on the site, will be subject to that amended privacy statement.