Privacy and Credit Reporting Policy

1. Introduction

MoneyMe Financial Group Pty Ltd ACN 163 691 236 Australian Credit Licence Number 442218 trading as MoneyMe (we, us or our) respects all customers, third parties, suppliers and visitors (you, your or yours) privacy 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). 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 (personal information).

This Privacy and Credit Reporting Policy (Privacy Policy) applies to all personal information collected by us, or submitted to us, whether offline or online, including information collected in connection with an application for credit or any other service we provide, or any personal information received by us from a credit reporting body from credit information held about you bearing on your credit worthiness (credit reporting information), or information about you such as your repayment history, the type and amount of credit provided to you, default and payment information, personal insolvency, court proceedings and any other publicly available information that relates to your credit worthiness (credit information) (collectively, credit information and credit reporting information, the credit-related information), or information submitted by you through our website, platforms and any mobile sites (Websites), applications, widgets and other mobile interactive features (collectively, our Apps), or through 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).

This Privacy Policy describes how we deal with information we collect and demonstrates our commitment to the protection of your privacy. By making an application for credit or any other service we provide, visiting the Sites and otherwise providing personal information to us, you are accepting and consenting to the practices described in this Privacy Policy. If you do not agree with any of the terms of this Privacy Policy, please do not use the Sites or submit any personal information to us.

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?

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-related information where you decide to apply for credit.

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.

The credit-related information we collect about you and hold 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 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 in you have committed a serious credit infringement.

We may collect and hold identification and transaction information about you for the purpose of our compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2008 (Cth). Your identity information may be verified with the issuer or official record holder. In certain cases we collect your personal information from third parties, such as credit reporting agencies, your nominated representative (such as a legal or financial adviser), your employer, or publicly available sources of 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 personal information from the Sites, such as when you visit, use or register on our Websites, Apps or Social Media Pages;
  • collect personal information from you when you contact, do business or interact with us by phone or email;
  • receive your personal or credit-related information 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
  • ask a credit reporting body for your credit report if you apply for credit.

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.

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;
  • to those involved in maintaining, reviewing and developing our business systems, procedures and infrastructure;
  • 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;
  • 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.

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.

Our Sites may contain hyperlinks to websites operated by third parties. We are not responsible for the content of such websites, or the manner in which those websites handle any personal information you provide. In these cases, your personal information may be collected by that third party and not by us and will be subject to that third party's privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, that third party's use or disclosure of your personal information.

6. 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.

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: for example, guarantors and security providers, credit bureaus, credit reporting bodies, other credit providers, 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, auditors, organisations that help identify illegal activities and prevent fraud, any data processors processing your information on our behalf, where applicable, third parties who provide related services or products in connection with our business such as our vendors, business partners, and any party assisting us in carrying out the purposes described above, parties which participate in joint marketing schemes with us, 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.

7. Overseas Disclosures

We may use the services of certain third party service providers which may have offices or other operations outside of Australia. As a result, your personal and credit-related information may be disclosed to recipients in those foreign countries. All service providers that have access to personal and credit-related information held by us are required to keep the information confidential and not to make use of it for any purpose other than to provide services in accordance with their engagement. We will take all steps that are reasonably necessary to ensure your personal and credit-related information is treated securely and in accordance with this Privacy Policy as well as applicable data protection laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the European Economic Area.

8. Notifiable Matters

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 matters, such as how we exchange your credit-related information with credit reporting bodies. We use the credit-related information that we exchange with the a credit reporting body to confirm your identity, assess your creditworthiness, assess and manage your application for products and services. Details of these matters can be viewed on our website and are also set out in the ‘privacy consent and electronic authorisation’ we will ask you to agree to at the time you apply for consumer credit. You may request to have these notifiable matters (and this Privacy Policy) provided to you in an alternative form, such as a hard copy.

9. Access and Correction of Personal and Credit Information

Individuals may request access to their personal and credit-related information unless we are permitted by law to withhold that information. We may charge a fee for our costs of retrieving and supplying the information to you. Individuals may also request the correction of any personal information which is inaccurate by contacting our Privacy Officer at privacy@moneyme.com.au. To the extent permitted by law, there are some exceptions where this access may be denied. If we deny you access to the personal or credit-related information we hold about you, or if we refuse to correct your personal or credit-related information, an explanation will be provided to you. To request access and seek the correction of personal information held by us, please email, call or write to us. We will endeavour to respond to any access or correction request within 7 working days of receipt.

10. 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.

11. 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 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.

12. 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.

13. Other Information We Collect

The Sites collect other information that may or may not be personal information. Other information includes information that does not reveal your identity, such as browser and device information, server log file information, App usage data, demographic information, location information and aggregated information. When you download and use an App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number. Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies.

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.

14.  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 privacy@moneyme.com.au. Once we receive your complaint, we will respond to you within a reasonable period of time, usually within 7 working days. 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 info@afca.org.au, or in writing to GPO Box 3, Melbourne VIC 3001. Or, you can contact the Office of the Australian Information Commissioner (OAIC). The OIAC can be contacted by phone: 1300 363 992. Website: www.oaic.gov.au

15. Variations to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time by publishing an updated version of this Privacy Policy on our Website and taking any further action as required by law, after which, your continued use of the Website or your provision of any further personal information will indicate your acknowledgement to the modified terms of this Privacy Policy.

This Privacy Policy was last updated on 15 June 2020.

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