MoneyMe Financial Group Pty Ltd ACN 163 691 236 Australian Credit Licence Number 442218 trading as MoneyMe (we, us or our) respects the privacy of all customers, third parties, suppliers and visitors (you, your or yours) and is committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles and the Privacy (Credit Reporting) Code 2014 (Credit Reporting Code).
Any personal or credit-related 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. We comply with the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and comply with the Credit Reporting Code.
2. What Kinds of Personal Information Do We Collect and Hold?
The Privacy Act defines personal information as information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
The personal information we collect and hold may include your contact details, such as your name, address, telephone numbers and email address, your personal details, such as date of birth, your employment information, residential status and information about your financial position, including your income, expenses, savings and assets and any (other) credit arrangements, 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, the length of time you have lived at your current address, and other information we consider relevant to assessment of your application for credit or any other service we provide. We also hold all records of your communications and other interactions with us.
Credit-related information means:
- Credit information, which is information about you such as your repayment history, the type and maximum amount of credit provided to you including when that credit was provided and when it was repaid, default (including overdue payments) and repayment history information, payment information, new arrangement information, personal insolvency (including details of any serious credit infringements), court proceedings and any other publicly available information that relates to your credit worthiness; and
- Credit eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.
We use your credit-related information to assess your eligibility to be provided with finance. Usually, credit-related information is exchanged between credit and finance providers and credit reporting bodies.
When you use our website, platforms and any mobile sites (Websites), applications, widgets and other mobile interactive features (collectively, our Apps), or our official social media pages that we control (our Social Media Pages) as well as through HTML-formatted email messages that we send to you (collectively, including the Social Media Pages, Apps and Websites, the Sites), we may collect other information.
Please note that we may use and disclose such other information which is not personal information for any purpose, except where we are required to do otherwise under applicable law for example, if we are required to treat that information as personal information under applicable law. In some instances, we may combine other information with personal information. If other information can be combined with personal information or can be used to build a profile of an individual (in a way which could be reasonably used to identify that individual), such other information will be treated by us as personal information.
3. How We Collect Your Personal Information
We collect personal information about you when it is reasonably necessary for one or more of our activities or functions. This personal information is collected in a number of ways, including through the Sites. For example, we may collect your personal information:
- from the Sites, such as when you visit, use or register on our Websites, Apps or Social Media Pages;
- directly from you when you contact, do business or interact with us by phone or email;
- from other sources, such as public databases, acquired contact lists, professional and other credit bodies (for example under reciprocal arrangements), your employer, regulators and government and statutory bodies; or
- credit reporting bodies (for your credit report if you apply for credit), mortgage and finance brokers, employers, and other people such as accountants and lawyers.
4. If We Do Not Collect Your Personal Information
The provision of your personal information is voluntary. However, if you cannot, or will not, provide us with the personal or credit-related information we reasonably require, we may not be able to confirm your identify, assess your application for a product or service, manage our relationship with you, contact you or otherwise interact with you, perform our statutory functions, or provide you with some or all of our credit products and services.
Note: where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information (for example, if you make general inquiries about interest rates or current promotional offers).
5. How We Use Your Personal Information
We will not collect or use your personal information or credit-related information unless it is lawful for us to do so. We collect and use personal and credit-related information for the following purposes:
- considering any application made by you for products or services offered by us, including credit and other services and applications;
- managing those products or services that we offer;
- to those involved in maintaining, reviewing and developing our business systems, procedures and infrastructure;
- to establish your identity;
- to exchange credit-related information with credit reporting bodies for the purpose of assessing and managing your application for products and services offered by us;
- to our partners in financial transactions, including financial institutions, merchants and payment organisations;
- to credit and fraud reporting agencies, debt collection agencies, and organisations involved in our normal business practices;
- fulfilling orders or requests for information, products or services (with your consent, if required);
- fulfilling our role as a credit provider, including maintaining customer records, providing information on our services, products and benefits;
- for promotional and marketing purposes, including communicating information about our products and services (with your consent, if required);
- for the purpose of referral or lead selling (with your consent, if required);
- monitoring, moderating and improving our Sites;
- conducting, managing and reporting on quality assurance reviews and audits;
- managing complaints;
- managing our risks and complying with our legal obligations;
- providing information to Australian regulators, government and statutory bodies;
- providing products and services, or information relating to such products and services (with your consent, if required);
- assessing or improving our products and services, as well as for training and quality purposes, including building profiles, monitoring, recording and analysing online interactions and communications between you and us; and
- providing information to third parties as authorised or required by law or a court or tribunal.
We have a legitimate interest in using your information in these ways. It is also fundamental to the nature of the service we provide. In some cases, it will be lawful for us to collect and use your personal and credit-related information, for example where it is necessary as part of our, or a third party's statutory function or because the law permits or requires us to.
6. Direct Marketing
In addition to the specific circumstances above, we will only use your personal information with your consent (if required under applicable data protection laws) when we process your personal information in order to send you carefully selected marketing materials about our products and services (or those of our third party partners) by email, text or push notification, depending on your account or operating system settings. You have the right to opt out of receiving such direct marketing at any time. If at any time you wish to stop receiving direct marketing messages from us you can let us know by contacting us. In your request, please indicate that you wish to stop receiving marketing communications from us.
7. Use and Disclosure of Personal Information
We do not use your personal or credit-related information or disclose it to another organisation unless it is reasonably necessary for one of the purposes described above, having regard to the nature of the information or the circumstances of collection we believe you would expect us to use the information or make the disclosure. For example, if it is required or authorised by law or court or tribunal, it is necessary to protect the rights, property, health or personal safety of a customer, the public or our interests, and it is unreasonable or impracticable to obtain your consent, the disclosure is necessary to assist any entity, body or person to locate a person who has been reported missing, we have reason to suspect that activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in, and we believe that the collection, use or disclosure is necessary in order for us to take appropriate action, it is necessary to obtain third party services, for example to carry out data analysis or provide information processing services (where use of your information by third parties is strictly controlled), it is for one of the purposes expressly permitted under applicable data protection and privacy laws or you have provided your consent.
We exchange credit-related information for the purposes of assessing your application for finance and managing that finance.
For avoidance of doubt, we may disclose your personal and credit-related information to:
- any of our related and associated companies, affiliates and subsidiaries, including those established in the future;
- guarantors and security providers, credit bureaus, credit reporting bodies;
- prospective funders or other intermediaries in relation to your finance requirements;
- other credit providers;
- any person who represents you, such as brokers, agents, financial advisors and people who act on your behalf;
- organisations involved in our funding arrangements (like loan purchasers and investors)
- other banks and financial institutions;
- organisations that help identify illegal activities and prevent fraud, any data processors processing your information on our behalf;
- third parties who provide related services or products in connection with our business such as our vendors;
- anyone where you have provided us consent;
- associated businesses that may want to market products to you;
- any party assisting us in carrying out the purposes described above;
- parties which participate in joint marketing schemes with us;
- to claims related providers, such as assessors and investigators who help us with claims;
- any agent, contractor or service provider who provides verification of identity, administrative, order processing, payment clearing, credit reference, debt collecting or other services necessary to the operation of our business;
- any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law;
- government agencies, statutory authorities and industry regulators;
- our auditors, consultants, accountants, lawyers or other financial or professional advisers and our sub-contractors or third party service or product providers as may be determined to be necessary or appropriate;
- organisations that provide products or services used or marketed by us; or
- to your employer, former employer, referees or identity verification services
8. Overseas Disclosures
9. Notifiable Matters
We exchange your credit-related information with credit reporting bodies. We use the credit-related information that we exchange with credit reporting bodies to confirm your identity, assess your creditworthiness, assess your application for finance or your capacity to be a guarantor, and manage your finance.
The information we may exchange with credit reporting bodies includes your identification details, what type of loans you have, how much you have borrowed, whether or not you have met your loan payment obligations. and if you have committed a serious credit infringement (such as fraud).
If you fail to meet your payment obligations in relation to any finance that we have provided or arranged, or if you have committed a serious credit infringement, we may disclose this information to a credit reporting body.
You have the right to request access to the credit-related information that we hold about you and make a request for us to correct that credit-related information if needed. See ‘Access and correction of Personal and Credit Information’ below for further information.
Sometimes your credit-related information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers. You can contact the credit reporting bodies at any time to request that your credit-related information is not used in this way.
You may contact the credit reporting bodies to advise them that you believe that you may have been a victim of fraud. Credit reporting bodies must not use or disclose your credit-related information for a period of 21 days after you notify them that you may have been a victim of fraud. You can contact any of the following credit reporting bodies for more information:
- Equifax Pty Limited – www.equifax.com.au;
- Illion (Australia) Pty Limited – www.dnb.com.au;
Experian Australia Credit Services Pty Limited – www.experian.com.au.
10. Updating your personal information
It is important to us that the personal information we hold about you is accurate and up-to-date. During the course of our relationship with you, we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure that the information we hold about you is accurate or complete.
11. Access and Correction of Personal and Credit Information
We will provide you with access to the personal and credit-related information we hold about you. You may request access to any of the personal and credit-related information we hold about you at any time. We may charge a fee for our costs of retrieving and supplying the information to you.
Depending on the type of request that you make, we may respond to your request immediately. Otherwise, we usually 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 or credit-related information, for example, if the information relates to existing or anticipated legal proceedings, if your request is vexatious, or if the information is commercially sensitive.
If we deny you access to the personal or credit-related information we hold about you, we will explain why.
If any of the personal or credit-related information we hold about you is incorrect, inaccurate or out-of-date, you may request that we correct the information by phoning us on 1300 329 037or by writing to us at email@example.com.
If appropriate, we will correct the personal or credit-related information at the time of your request. Otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected your personal or credit-related information within 30 days.
We may need to consult with other finance providers or credit reporting bodies or entities as part of our investigation.
If we refuse to correct personal or credit-related information, we will provide you with our reasons for not correcting the information.
12. Residents in the European Economic Area
If you are a resident in the European Economic Area, you have the following rights in relation to your personal information (where applicable):
- You have the right to request a copy of the personal information we are processing about you. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.
- You have the right to have incomplete or inaccurate personal information that we process about you rectified.
- You have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
- You have the right to restrict our processing of your personal information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
- You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
- Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
- If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.
To make a request to exercise any of these rights in relation to your personal information, please email, call or write to us.
13. How Long Do We Keep Your Personal Information?
We will only retain your personal and credit-related information for as long as is necessary for the purpose for which that personal information was collected and to the extent permitted by applicable laws. When we no longer need (or are otherwise obliged under any law) to use personal or credit-related information, we will remove it from our systems and records and/or take steps to anonymise it so you can no longer be identified from it.
14. Security of Personal Information
We use reasonable organisational, technical and administrative measures and security safeguards to protect, as is reasonable in the circumstances, the personal information we hold from misuse, loss, interference and/or unauthorised access, use, disclosure or alteration of information under our control. Where practicable, we implement measures to require organisations to whom disclosure is made to comply with applicable data protection and privacy laws. If a third party is given access to personal or credit-related information, we take reasonable steps to ensure that the information is held securely and used only for the purpose of providing the relevant service or activity. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem.
15. Sensitive information
We will only collect sensitive information about you with your consent. 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. For example, if you submit an application with us to finance a cosmetic surgery procedure (or some other medical procedure), we may collect your health information for the purpose of assessing your application and may disclose this health information to your cosmetic surgery provider.
16. Privacy Concerns
If you would like any further information about our handling of personal information, or to make a complaint about our handling of your personal information, or you believe there has been a breach by us of the Privacy Act or the credit reporting provisions of the Credit Reporting Code, please lodge a complaint addressed to our Privacy Officer at firstname.lastname@example.org.
We will acknowledge your complaint within seven days and aim to resolve the complaint as quickly as possible. We will provide you with a decision on your complaint within 30 days.
If you are unsatisfied with the outcome of your complaint, you may contact us further to advise of your concerns and, if we are unable to reach a satisfactory resolution, you may wish to take your complaint to the:
- Australian Financial Complaints Authority, which can be contacted by phone on 1800 931 678, by email at email@example.com, or in writing to GPO Box 3, Melbourne VIC 3001; and/or
- Office of the Australian Information Commissioner (OAIC). The OIAC can be contacted by phone: 1300 363 992. Website: oaic.gov.au
17. Further information
You may request further information about the way we manage your personal or credit-related information by phoning us on 1300 329 037or by writing to us at firstname.lastname@example.org.
You may request this policy in an alternative form by phoning us on 1300 329 037or by writing to us at email@example.com.