Canni Money - Privacy Policy

CANNI MONEY PRIVACY POLICY

1. INTRODUCTION

This policy outlines how Canni Money Pty Ltd ACN 645 263 485 (Canni, we, us or our) seeks to manage personal information (including credit-related personal information) about individuals, including Canni’s customers and prospective customers, in accordance with the Privacy Act 1988 (Cth) (the Privacy Act), the Australian Privacy Principles set out in the Privacy Act and the Privacy (Credit Reporting) Code 2014 (the CR Code) as applicable. Canni Money Pty Ltd ACN 645 263 485, Credit Representative Number CRN 543171, of Australian Credit Licence Number 506104.

2. WHAT IS PERSONAL INFORMATION?

Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true.

3. WHAT IS CREDIT INFORMATION?

Credit information may include, for example, information about:

your consumer credit accounts (past and present), including credit limits and repayment history;
consumer credit payments that you are overdue in making as a borrower or guarantor;
any Australian court judgement against you in relation to credit you received or applied for;
you that is in the National Personal Insolvency Index; and
your credit worthiness that is publicly available.

Consumer credit means credit that is intended to be used wholly or primarily for personal, family or household purposes or in relation to residential property for investment purposes.

4. WHAT TYPES OF PERSONAL AND CREDIT INFORMATION DO WE COLLECT?

Below we summarise some of the main types of personal information that we collect. In addition to these types of personal information, we may collect other personal information as permitted or required by law.

4.1 Customers and prospective customers

We may collect a range of personal or credit information to:

enable us to assess, offer and manage any products and services requested by our customers and prospective customers;
respond to queries from our customers and prospective customers; and
allow customers, prospective customers or other members of the public to enter a competition or other activity that we run. The types of personal information that Canni collects about such people (and about employees and officers of customers and prospective customers and other individuals who act or propose to act as guarantors for customers) may include name, date of birth, residential address, postal address, email address, telephone numbers, gender, occupation, place of work, nominated bank account details, tax file number, medicare number, transaction and account balance information, information about product preferences, online behaviour and response to various marketing initiatives, and other credit information. Canni may also require personal information to confirm your identity, including online verification, such as information from or copies of your:
- driver’s license;
- passport;
- utility bills.

The types of credit information that Canni collects about you may include information about:

the type and amount of credit sought in a credit application made by you or by a person for whom you are, or propose to be, a guarantor, and the names of relevant credit providers to whom an application was made;
details of other credit providers to you, including the nature and maximum amount of credit to be provided and the dates of those arrangements;
any defaults by you, or a person for whom you are or propose to be a guarantor, on other credit facilities;
payments or any new arrangements made by you in respect of any defaults previously recorded with a credit reporting body;
details about credit-related court proceedings and personal insolvency information related to you;
whether, in the opinion of another credit provider, you have committed a serious credit infringement;
information about your history of making repayments in relation to other credit facilities; and
your credit worthiness, such as your credit score and risk rating, obtained from a credit reporting body.

4.2 Working for Canni – prospective employees

If you wish to be employed or engaged by Canni (directly or indirectly, e.g. as an employee of a labour hire company) we will require personal information about you that may include your:

name;
residential address, postal address and email address;
telephone number;
academic results and qualifications;
expertise and experience;
employment history;
personal interests;
current salary and salary expectations; and
background information about you including, for example, your criminal record.

4.3 Suppliers

If you are a supplier of goods or services to Canni, or are employed or engaged by such a supplier, we may collect personal information about you including:

name;
business address and email address;
telephone number; and
position.

5. HOW DO WE COLLECT YOUR PERSONAL AND CREDIT INFORMATION?

The main way we collect personal and credit information about you is when you give it directly to us, or when we receive it from a third party whose details you give us e.g. a referee (if you seek to work for us) or a guarantor or anyone else listed on a credit application form. We often gather this information through application forms, via surveys or through other communications via email or telephone (for example when you contact us to ask for information).

We may also collect your personal and credit information from external sources such as:

employers, accountants, real estate agents or any referees you nominate;
persons authorised by you to provide us with information (such as a lawyer, financial adviser or intermediary);
other credit providers;
credit reporting bodies;
third-party brokers;
public sources such as the National Personal Insolvency Index;
third party identity management providers (for example Google or LinkedIn);
regulators and other government entities; and
our related bodies corporate.

Canni may also collect your personal information in any of the following ways:

social media: if you access a social media page operated by us or communicate with us via social media platforms, the information we collect about you may include information or content you have permitted the third party social media service to share with us;
our website: each time you visit our website, we may collect information about your use of the website. This may be from internet browsing or accessing our website via mobile or tablet applications;
search engines, third party websites and social media pages: for example, if you apply for a job with us, we may conduct background checking through these means;
cookies: we may use technology called ‘cookies’ when you visit our website. Cookies are generally not personal information and do not comprise personal information, however cookies can record information about your visit to our website. The cookies we send to your computer cannot read your hard drive or command your computer to perform any action. They are designed so that they cannot be sent to another site or be retrieved by any non-Canni site. Your web browser may allow you to turn off cookies. Turning off cookies may restrict your use of our website and access to your accounts;
private messaging: we may invite you to send your details to us via private messaging, for example, to answer a question about your account;
participation in activities or competitions: you may also be invited to share your personal information through secure channels to participate in other activities, such as competitions; and
derived credit information: we may derive credit information from your dealings with us in relation to credit, e.g. when you make payments to us. We may also combine credit reporting information from a credit reporting body with our own information relevant to your creditworthiness, to derive further information about your creditworthiness which we may use to determine whether to offer credit to you (and if so, on what terms).

To enable Canni to assess a credit application by you or in which you are listed, Canni may obtain a report from a credit reporting body setting out credit reporting information about you, and setting out any other information in relation to the commercial credit activities of all individuals listed on the credit application.

Where you have consented, Canni may obtain from, and give to, any credit provider named in a credit application and any credit provider that may be named in a credit report issued by a credit reporting body, information about your credit arrangements.

6. WHY DO WE NEED YOUR PERSONAL AND CREDIT INFORMATION?

Canni collects personal and credit information in order to:

understand and manage our customers’ needs;
provide our customers with products and services;
identify you;
develop and improve our products, services and business;
identify your behaviour, habits and preferences;
market Canni’s and others’ products and services to you, including by sending you electronic messages (such as email, SMS) subject at all times to our obligations under the Spam Act 2003 (Cth);
assess your creditworthiness;
assist you with enquiries or complaints;
participate in the credit reporting system, including to provide credit information to credit reporting bodies and assist other credit providers in accordance with applicable legislation;
manage our human resources functions;
enable us to comply with our legal and regulatory obligations;
assist us to manage risk;
enable us to manage complaints and legal proceedings;
enable the management and recovery of debts;
consider you for employment or a contractor position with us;
manage our relationships with our investors;
do business with our suppliers of goods and services (you may be a supplier, or employed or engaged by a supplier);
notify you if you have won a competition;
carry out research and analysis related to our products and services;
protect our rights and property and those of our customers; and
pursue any other purpose required or permitted by law.
We may also use your credit information to:
assess an application for credit;
assist you to avoid defaulting on your credit obligations;
assess whether Canni ought to accept you as a guarantor in relation to an application for credit; and
assess whether you have committed a serious credit infringement.

If you do not provide us with your personal information or credit information, our ability to provide you with a specific product or service may be limited. In general, we will only collect sensitive information about you from you directly, and only where it is reasonably necessary for our business functions and activities.

7. HOW WE USE AND DISCLOSE YOUR PERSONAL AND CREDIT INFORMATION?

We may use and disclose your personal information and credit information for any of the purposes outlined above (that purpose being the ‘primary purpose’), and will only use it for another purpose (‘secondary purpose’) if you consent or would reasonably expect us to do so. In the case of sensitive information however, we will only ever use that information for a secondary purpose that is directly related to the primary purpose, or as otherwise required by law.

Further information about specific uses we may make of your personal information and credit information, and third parties to which we may disclose your personal information and credit information, is set out below.

The information below is not intended to be exhaustive and there may be other third parties to which we provide your personal information or credit information where required or permitted by law.

7.1 Personal information disclosure

The persons or organisations to which we disclose your personal information could include:

our related entities to facilitate our and their internal business processes;
to prospective funders or other intermediaries in relation to your finance requirements;
to other organisations that are involved in managing or administering your finance such as third-party suppliers, printing and postal services, call centres;
other organisations with whom we have affiliations so that they may provide you with information about their products and services and various promotions, where we consider that they may be of interest to you;
third party service providers who assist us in operating our business (for example, credit reporting bodies, marketing service providers, third party identity management providers and other technology service providers);
to prospective funders or other intermediaries in relation to your finance requirements;
debt collectors;
our financial advisers, consultants, insurers, legal advisers, auditors and other professional services providers;
organisations involved with us in a corporate re-organisation or involved in a transfer or potential transfer of all or part of the assets or business of our organisation, and the advisers of and professional services providers to those organisations;
organisations involved in the provision or potential provision of finance to, or any capital raising by, Canni, and the advisers of and professional services providers to those organisations;
organisations involved in our payments systems including financial institutions, merchants and payment organisations;
regulators and law enforcement agencies; and
other organisations as required or authorised by law or where you have given your consent.

Where practical, Canni will use reasonable commercial efforts to ensure third parties to whom we disclose your personal information are subject to confidentiality requirements in relation to that information.

7.2 Credit information disclosure

(a) Disclosure to a credit reporting body

We may disclose credit-related personal information to a credit reporting body in order to obtain credit eligibility information about you or if you fail to meet your payment obligations or commit a serious credit infringement. Where the information disclosed is default information in relation to consumer credit, Canni will not disclose it to the credit reporting body unless at least 14 days have passed after we have given written notice of our intention to disclose this information.

We may disclose any information, including personal information, in relation to commercial credit, to a credit reporting body or to another credit provider.

Canni may disclose credit information to the following credit reporting bodies:

Equifax Australia
Website: https://www.equifax.com/personal/credit-report-services/
Phone: 13 8332

Experian Australia Credit Services Pty Ltd
Website: www.experian.com.au
Email: creditreport@au.experian.com
Phone: 1300 783 684

Credit reporting bodies are required to have a policy about how it manages credit-related personal information. If you would like to read this policy, visit the credit reporting body’s website.

You have the right to request that a credit reporting body does not use your credit reporting information for the purpose of pre-screening or direct marketing. You also have the right to request that a credit reporting body does not use or disclose your credit reporting information if you believe on reasonable grounds that you have been, or are likely to be, the victim of fraud (e.g. if you suspect someone may use your identity to apply for credit). These requests should be made directly to the credit reporting body.

(b) Disclosure to others

From time to time Canni may also disclose credit information about you to:

a potential guarantor or person who proposes to provide security for credit, where you are the borrower or are associated with the borrower and have consented to this;
a debt collection agency for the purposes of collecting an overdue payment;
a person for an external dispute resolution purpose;
any entity to which we are authorised or required by law or a court/tribunal to disclose it;
a regulatory or law enforcement body if we believe on reasonable grounds you have committed a serious credit infringement;
an entity or their professional, legal or financial advisers for specified commercial purposes permitted under the Privacy Act;
a guarantor or a person who has provided security for credit, where you are the borrower or are associated with the borrower and have consented to this (or without your consent where we enforce a guarantee for commercial credit or consumer credit);
any specific parties that we have advised you, at the time of collection of your personal or credit information, that we might disclose your credit information to such as an employer, estate agent or referee;
any other person or entity where you have given you consent, and
any other person or entity as otherwise permitted in accordance with this policy.

7.3 Direct marketing

Direct marketing involves communicating directly with you for the purpose of promoting goods or services to you and providing you with special offers from Canni, its related entities or its third-party business partners. Direct marketing can be delivered by a range of methods including mail or telephone.

We may use and disclose your personal information for the purpose of direct marketing to you where:

you have consented to us doing so; or
it is otherwise permitted by law, including the Do Not Call Register Act 2006 (Cth).

In addition, as outlined above we may contact you by electronic means (SMS, email, etc) for the purposes of the above, subject to the Spam Act 2003 (Cth).

You can unsubscribe from our direct marketing, or change your contact preferences, by contacting us (our contact details are in section 11 of this policy).

8. USING GOVERNMENT IDENTIFIERS

If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.

9. DO WE SEND INFORMATION TO OVERSEAS RECIPIENTS?

Canni actively avoids offshore hosting and servicing of customer information and currently does not disclose your personal information and credit information to overseas recipients.

However, should Canni disclose personal information or credit information to an overseas recipient:

We shall take reasonable steps to ensure the overseas recipient does not breach the Australian Privacy Principles in relation to that information; and
we will only do so where we reasonably believe that:
- the overseas recipient is subject to a law, or binding scheme, that has the effect of protecting the information in a way that, overall, is at least substantially like the way the Australian Privacy Principles protect the information; and
- you can take action to enforce that law or scheme; and/or
- the Australian Privacy Principles otherwise allow it.

10. HOW DOES CANNI HOLD YOUR PERSONAL AND CREDIT INFORMATION?

The security of your personal and credit information is important to us.

We store your personal information in different ways, including in paper-based, electronic and other formats. We may use cloud computer storage facilities to store the personal and credit information we hold about you.

We take reasonable precautions to protect the personal information and credit information we hold from:

misuse, interference and loss; and
unauthorised access, modification or disclosure.

These include electronic and physical security measures and ensuring all our staff are trained to respect the security and confidentiality of our customers’ information.

If we no longer need your personal or credit information and are not required by law to keep it, we will take reasonable steps to delete, destroy or de-identify it.

11. HOW CAN YOU ACCESS AND CORRECT YOUR PERSONAL AND CREDIT INFORMATION?

Canni takes reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. Accuracy depends on the information provided to Canni.

You have the right to seek access to your personal information held by Canni and to request correction of the information. If you wish to do so, you may contact us at hello@cannimoney.com or by phone on +61 2 9238 4246.

We may require evidence of your identity as part of the process of providing you with access to your personal information or correcting your personal information.

There are no fees associated with making a request to access or correct your information. However, we may charge a reasonable fee for processing an access request, to account for locating the information and supplying it to you.

We may refuse to give you access to the personal information we hold about you if we reasonably believe that giving you access would pose a serious threat to the life, health or safety of an individual, if giving access would have an unreasonable impact on the privacy of other individuals, or if the request is frivolous or vexatious. Other grounds for refusal to give access may also apply under the Privacy Act.

12. COMPLAINTS

If you are dissatisfied with how we manage your personal or credit information in accordance with the Privacy Act or Credit Reporting Code, you can register a complaint directly with Canni’s Privacy Officer in the first instance.

All complaints need to be lodged in writing.

Canni will follow these steps to address and manage your complaint:

make a record of your complaint;
within 7 business days of receiving a complaint, acknowledge your complaint in writing; and
within 30 business days of receiving a complaint, investigate the complaint and provide a response to you in writing.

If you wish to make a complaint, please contact us on:

Phone: +61 2 9238 4246
Email: hello@cannimoney.com
Mail: Privacy Officer, Canni Money
Level 29, 2 Chifley Square, Sydney, NSW 2000
Website: https://www.cannimoney.com/

If you are dissatisfied with how a complaint has been handled, you can lodge a complaint directly with the Australian Information Commissioner www.oaic.gov.au or with the Australian Financial Complaints Authority (AFCA). AFCA can be contacted on:

Email: enquiries@oaic.gov.au
Fax: 02 9284 9666
Mail: GPO Box 5218
Sydney NSW 2001 Website: www.oaic.gov.au

or you can lodge a complaint directly with the Australian Financial Complaints Authority (AFCA). AFCA:

Phone: 1800 931 678
Email: info@afca.org.au
Fax: 03 9613 6399
Mail: GPO Box 3
Melbourne VIC 3001
Website: www.afca.org.au

13. CHANGES TO THIS POLICY

We may modify or replace this policy at any time. We will publish any modified or replacement policy on our website at https://www.cannimoney.com/. Any changes come into effect upon publication.

By continuing to access or use our products or services after those changes become effective, you agree to the changed policy.

14. FURTHER INFORMATION

For more information about any issue relating to this policy, please contact us at:

Phone: +61 2 9238 4246
Email: hello@cannimoney.com
Mail: Privacy Officer
Level 29, 2 Chifley Square, Sydney, NSW 2000
Website: https://www.cannimoney.com/

For information in relation to privacy in general, you can visit the Australian Information Commissioner’s website at www.oaic.gov.au.

CANNI MONEY PRIVACY COLLECTION STATEMENT

Canni Money Pty Ltd ACN 645 263 485 (“Canni”) collects your personal information for our business purposes and so as to provide you with requested services, or as otherwise outlined in our privacy policy located here . If you do not provide us with your personal information, we may not be able to provide you with our services. We may share your personal information with our related bodies corporate or other parties for the purposes of providing you with requested services, or as otherwise outlined in our privacy policy. For details on how you can access your information, correct it, or to make complaints and how we will handle them, please see our privacy policy.