LOAN TRADING AUSTRALIA PRIVACY POLICY
1. INTRODUCTION
This policy outlines how Loan Trading Australia Pty Ltd ACN 612 904 579 (Loan Trading Australia, we, us or our) seeks to manage personal information (including credit-related personal information) about individuals, including Loan Trading Australia’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.
Loan Trading Australia is not a credit provider but can assist you in dealing with credit providers and credit reporting bodies. For example, Loan Trading Australia can help you get your credit score from a credit reporting body without leaving a ‘footprint’ of the check on your credit history. Loan Trading Australia can then provide that credit score to our related body corporate Canni Money which can make a tailored credit offer or refer your details to another appropriate credit provider.
The ways in which Canni Money manages personal and credit related information is detailed in the Canni Money Privacy Policy, which may be found at https://cannimoney.com/privacy. “Canni Money” refers to 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 Loan Trading Australia 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, internet banking log-in details, tax file number, transaction and account balance information, information about product preferences, online behaviour and response to various marketing initiatives, and credit information. Loan Trading Australia may also require personal information to confirm your identity, such as information from or copies of your:
- driver’s license;
- passport;
- utility bills.
The types of credit information that Loan Trading Australia 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 Suppliers
If you are a supplier of goods or services to Loan Trading Australia, 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.
Loan Trading Australia 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 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-Loan Trading Australia 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; and
- 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.
6. Why do we need your personal and credit information?
The reason we may wish to collect, hold, use and disclose your personal information is so that we can manage and administer the products we provide and to run our business efficiently. You may be an applicant, a current, previous or prospective customer, contractor, job applicant, supplier, partner or party with whom we do or have done business or may do business with in the future.
As a financial services provider, a major purpose for which we collect, hold, use or disclose personal information is to provide you with a tailored personalised interest rate.
Other purposes for which we may collect, hold, use or disclose your personal information include:
- responding to your queries;
- understanding and managing our customers’ needs;
- providing our customers with products and services;
- 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;
- assisting you in dealing with credit reporting bodies (e.g. to obtain your credit score);
- to pass information about you (upon your instruction) to Canni Money, and to review or transfer back to you information about estimated interest rates with Canni Money and other credit providers based on your credit score and other personal information;
- establishing, managing, administering, evaluating and improving our products or services, including research, planning, service development, security and risk management;
- identifying you and investigating and protecting ourselves against fraud and unlawful activities;
- complying with laws which apply to us, assisting regulatory authorities and protecting our lawful interests; and
- subject to our legal obligations and your requests to opt out, to provide you with promotional information about us and our products on an ongoing basis, by any means including telephone, email and other electronic messages (we may also share your personal information with Canni Money and our other related bodies corporate and joint promotion partners for this purpose), subject at all times to our obligations under the Spam Act 2003 (Cth).
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;
- other organisations with whom we have affiliations so that they may provide you with information about our 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, Loan Trading Australia, 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, Loan Trading Australia 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, Loan Trading Australia 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.
Loan Trading Australia may disclose credit information to the following credit reporting bodies:
Equifax Australia Equifax, Consumer Resolutions
PO BOX 964
North Sydney NSW 2059
customercomplaintsAUcorrection@vedaequifax.com.au
www.equifaxmycreditfile.com.au
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 of 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 Loan Trading Australia 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 Loan Trading Australia, 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?
Loan Trading Australia 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 Loan Trading Australia 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;
- the Australian Privacy Principles otherwise allow it.
10. HOW DOES LOAN TRADING AUSTRALIA 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?
Loan Trading Australia 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 Loan Trading Australia.
You have the right to seek access to your personal information held by Loan Trading Australia 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 4256.
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 Loan Trading Australia’s Privacy Officer in the first instance.
All complaints need to be lodged in writing.
Loan Trading Australia 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 4256.
Email: hello@cannimoney.com
Mail: Privacy Officer, Loan Trading Australia
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 4256.
Email: hello@cannimoney.com
Mail: Privacy Officer, Loan Trading Australia
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.
LOAN TRADING AUSTRALIA PRIVACY COLLECTION STATEMENT
Loan Trading Australia Pty Ltd ACN 612 904 579 (“LTA”) 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.