PRIVACY POLICY

Ensuring that we manage your personal information securely and consistently with the Privacy Act is a top priority for all of us at Billfix, (Billfix, we, us, our) .This policy is intended to help you understand how we manage the personal information that we collect about you, how you can seek access to and correction of that information and, if necessary, how you can make a complaint relating to our handling of that information. Unless stated otherwise, this policy is relevant to the personal information of both our current and former customers, as well as other individuals we may deal with (for example, guarantors, directors and shareholders relating to our customers or individuals we deal with in other capacities as part of our business).

For information about our management of your credit-related information, please see our CREDIT REPORTING POLICY below which contains information about credit reporting, including the credit reporting bodies with which we may share your credit information.

The nature of the personal information we collect and hold, and where it comes from, will vary according to the circumstances in which we are dealing with you (for example, if you are a customer, according to the specific product or service we are providing). This information may include:

• information we collect from you, persons acting on your behalf, or our affiliates, on applications or other documentation or communications, such as your name, residential and business addresses, telephone numbers, email and other electronic addresses, nationality, tax domicile, associations with politically exposed persons, occupation, employment details, assets, expenses, income, dependents and details about your business dealings and other events in your life;

• information about your transactions and products with us, our affiliates, or third parties, such as account balances, payment history, credit history and details about account activity and product use;

• sensitive information, including health information (for example, health information you provide to us when you make a hardship application in connection with a loan);

• Australian or foreign government identifiers such as your tax file number, ABN, Medicare card number, passport number or pension card number (for example, to verify your identity at the time you request a product or service);

• other details relating to your relationship with us or our affiliates or third parties, including if we deal with you in a capacity other than a customer (for example, information about agreements or other arrangements or transactions you may have with us).

• location information, IP address and any third party sites you access when you visit our websites or mobile apps.

We usually collect your personal information directly from you. However, sometimes we may need to collect personal information about you from affiliates or third parties for the purposes described below. The circumstances in which we may need to do this include, for example, where we need information from a third party to assist us to process an application (such as to verify information you have provided or to assess your circumstances) or to assist us to locate or communicate with you.

Your telephone calls and conversations with a Billfix representative may be recorded and monitored for quality, training and verification purposes.

We may hold your personal information in physical form or in electronic form on our systems or the systems of our service providers.

The personal information we hold about you is protected by physical, electronic, and procedural safeguards and we also require our service providers that hold and process such information on our behalf to follow appropriate standards of security and confidentiality.

In order to satisfy our legal obligations we may need to retain your information even after a transaction has come to an end (subject to our obligations under the Privacy Act).

We train people who work for us on how to handle personal information appropriately and we restrict access to what is necessary for specific job functions.

 

We will only collect, hold, use and disclose your personal information as reasonably necessary for our business purposes and as permitted by law. These purposes may include:

• processing a product application or service request (including verifying a person's identity for these purposes);

• managing our products and services or other relationships and arrangements, including processing receipts, payments, invoices and managing reward programs;

• evaluating and monitoring credit worthiness;

• detecting and preventing fraud and other risks to us and our customers and assessing insurance risks and claims;

• responding to inquiries about applications or other products, services or arrangements;

• understanding our customers' needs and offering products and services to meet those needs;

• researching and developing our products and services and maintaining and developing our systems and infrastructure (including undertaking testing);

• undertaking securitisation activities and other activities relating to funding and capital requirements;

• allowing our affiliates and selected companies to promote their products and services to customers;

• assessing, processing and investigating claims;

• promotions and events, including competitions and ticket offers;

• dealing with complaints;

• meeting legal and regulatory requirements. Various Australian may expressly require us to collect and / or disclose your personal information, or we may need to do so in order to be able to comply with other obligations under those laws. Such laws include the National Consumer Credit Protection Act (for example, to comply with responsible lending requirements), the Anti-Money Laundering and Counter-Terrorism Financing Act (for example, to comply with identity verification requirements), the Personal Property Securities Act and State and Territory real property and security interests laws (for example, to register and search for security interests), the Financial Sector (Collection of Data) Act, the Corporations Act and other regulatory legislation (for example, requiring us to maintain client and transaction records, to provide information relating to your deposits and loans to APRA for prudential and monitoring purposes and to make reports and provide other information to regulators such as ASIC) and the Taxation Administration Act, the Income Tax Assessment Act and other taxation laws (for example, to comply with information requests issued by the Commissioner of Taxation);

• any purpose relating to organisations that have, or are wishing to acquire an interest in any part of our business from time to time; and

• enforcing our rights, including undertaking debt collection activities and legal proceedings.

In common with many organisations, we obtain services from other Billfix entities and external service providers, and your information may be provided to them for this purpose. We may also need to disclose your personal information to other Billfix entities and to third parties for the purposes listed above.

Third parties to whom we disclose your personal information may include:

• our related Billfix companies in Australia;

• sales agents and organisations that carry out functions on our behalf including card schemes, mailing houses, printers and call centre operators;

• legal, settlement and valuation service providers;

• data processing and market research service providers;

• regulatory bodies in Australia;

• financial and other advisors;

• participants in financial and payment systems, such as banks, credit providers, clearing entities and credit card associations;

• insurers, assessors and underwriters;

• brokers, introducers and other distributors;

• your guarantors and security providers;

• debt collectors;

• providers of loyalty incentives, rewards and other benefits in connection with a Billfix account or service;

• other companies that we partner with to provide products and services, and their service providers;

• external dispute resolution schemes (for example, the Australian Financial Complaints Authority);

• organisations that have acquired, or are wishing to acquire an interest in any part of our business from time to time; and

• credit reporting bodies and other information providers. We may disclose your sensitive information for the purposes of assessing or approving a hardship application, and credit reporting bodies for the purposes of reporting if you have a hardship arrangement;

You are entitled under the Privacy Act to access personal information we hold about you, please contact us using the contact details below.

Given the range and diversity of Billfix’s operations in Australia, to help us locate and provide the information you request, we would ask that you be reasonably specific about the information you require.

We will need to validate the identity of anyone making an access request, to ensure that we do not provide your information to anyone who does not have the right to that information.

If you are seeking information on another person's behalf, we will require authorisation from that individual.

Gaining access to your personal information is subject to some exceptions allowed by law. Factors affecting a right to access include where:

• we reasonably believe that access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;

• access would have an unreasonable impact on the privacy of others;

• the request for access is frivolous or vexatious;

• the information relates to a commercially sensitive decision making process;

• access would be unlawful;

• denying access is required or authorised by or under an Australian law or a court / tribunal order;

• access would prejudice enforcement activities or the taking of appropriate action in relation to unlawful activity or serious misconduct;

• the information relates to existing or anticipated legal proceedings between you and Billfix and would not be accessible by the process of discovery; or

• the information would prejudice negotiations with you.

There is no charge for making an access request but an administration fee may apply for providing access in accordance with your request. Your request will usually receive a response within 30 days.

We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date and relevant. However, if you believe that this is not the case in relation to any personal information we hold about you, you have the right under the Privacy Act to request that we correct that information. If you would like to do so please contact us using the contact details below.

If we do not agree with a request to correct information we hold in relation to you we will give you notice in writing as to our reasons and the mechanisms available to you to complain about our decision. You may also request us to associate a statement with that information to the effect that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading so that it is apparent to users of the information.

If you are seeking to correct information on another person's behalf, we will require authorisation from that individual.

If you have reason to believe that we have not complied with our obligations under the Privacy Act in relation to your personal information, we urge you to raise this with our Customer Advocacy Unit.
There are three ways you can lodge your complaint:

By telephone
Call 07 55188217 (within Australia) between 9 AM – 5 PM
Monday to Friday (AEST).

In writing
Mail your written complaint to:
Customer Relations Unit
PO Box 4210, Nerang QLD 4211

We will investigate all complaints and respond to you as soon as practicable. If we find a complaint justified, we will resolve it. If necessary, we will change policies and procedures to maintain our high standards of performance, service and customer care.

If you are not happy with the way your privacy-related complaint is being handled, you can also contact the Privacy Officer using the contact details below.If you wish to find out more information, or raise any specific or general concerns, about Billfix and our Privacy Policy and privacy practices, the contact details are as follows:

By telephone
Billfix: 07 55188217

In writing
Privacy Officer
PO Box 4210, Nerang QLD 4211

Please do not include account numbers or other sensitive data in emails, since it may not be secure.

CREDIT REPORTING POLICY

This policy sets out Billfix’s approach to the collection, handling and disclosure of your consumer credit-related information, including information about your credit applications and credit accounts with us and your credit reporting information that we obtain from credit reporting bodies (CRBs).

This policy is relevant to current and former credit customers, as well as other individuals we deal with in connection with credit we provide (such as guarantors and directors).

For information about our management of your other personal information, which includes commercial credit-related information, please see our Privacy Policy above

We have currently do not engage in Comprehensive Credit Reporting, also known as 'Positive Bureau' but reserve the right to do so. This will enable credit providers to make more informed credit decisions. If we engage in Comprehensive Credit Reporting then we may collect, hold and disclose various types of credit-related information, including:

• your current and prior names and addresses, age, occupation (including the name of your employer) and your driver's licence number;

• that you have applied for consumer or commercial credit (including the name of each relevant credit provider), the type and amount of that credit and the fact we have accessed your consumer credit information to assess a relevant application;

• that we and other credit providers are or have been a provider of credit to you and the type, characteristics and maximum amount of credit that we have provided or will provide;

• the date that any credit contract we or other credit providers have or had with you was entered into and the date that it is terminated or otherwise ceases;

• your repayment history i.e. whether in relation to credit facilities provided by us or other credit providers, you have made payments when due and if not when overdue payments have been made;

• payments owed to us or another credit provider, in connection with credit provided to you or in relation to which you are a guarantor, overdue for more than 60 days (and, if you subsequently repay any such overdue payment, the fact of that repayment);

• whether in our or another credit provider's opinion you have committed a serious credit infringement;

• whether you have entered into arrangements (including financial hardship arrangements) with us or other credit providers in connection with credit provided to you;

• court proceedings information, personal insolvency information and credit-related publicly available information;

• scores, ratings, summaries, evaluations and other information relating to your credit worthiness which is derived by us or by CRBs wholly or partly on the basis of the information above;

• certain administrative information relating to credit, such as account and customer numbers.

While the Privacy Act uses a variety of terms to refer to the information above, to make it easier to read this policy, we refer to it below collectively as "credit information".

This information may be collected in a number of ways including:

• where provided by you directly to us or by persons acting on your behalf (such as on applications or other forms);

• where provided by credit reporting bodies and other credit providers;

• where such information is in the public domain; and

• where such information is derived by us from your usage and (where applicable) repayment of any account held with us or other credit providers associated with us.

We may hold your credit information in physical form or in electronic form on our systems or the systems of our service providers.

The credit information we hold about you is protected by physical, electronic, and procedural safeguards and we also require our service providers that hold and process such information on our behalf to follow appropriate standards of security and confidentiality.

We train people who work for us on how to handle credit information appropriately and we restrict access to what is necessary for specific job functions.

We may collect, hold, use and disclose your credit information as reasonably necessary for our business purposes and as permitted by law. These purposes include:

• to form decisions as to whether to provide you, or an entity associated with you, with credit or to accept you as a guarantor;

• to derive scores, ratings, summaries and evaluations relating to your credit worthiness which are used in our decision-making processes and ongoing reviews;

 

• to manage credit we may provide, including to determine whether you are eligible to receive particular offers and invitations, to deal with our mortgage insurers and to develop our services and maintain and develop our systems and infrastructure;

• to participate in the credit reporting system and providing information to CRBs as permitted by Part IIIA of the Privacy Act and the Credit Reporting Code;

• to undertake securitisation activities

• to assist you to avoid defaulting on your credit-related obligations;

• to undertake debt recovery and enforcement activities, including in relation to guarantors, and to deal with serious credit infringements;

• to deal with complaints and meet legal and regulatory requirements; and

• to assist other credit providers to do the same.

(Some credit information may only be used or disclosed under the Privacy Act for some of these purposes or in some circumstances).

We may disclose your credit information to CRBs for purposes such as those described above where the Privacy Act permits us to do so. For example, if you fail to meet your payment obligations in relation to consumer credit provided by us or if you commit a serious credit infringement we may be entitled to disclose this to CRBs.

CRBs may include credit information provided by us in reports provided to credit providers to assist them to assess your credit worthiness.

We may share credit information with the following CRBs:

Equifax

Equifax Australia Information Services and Solutions Pty Limited
PO Box 964
North Sydney NSW 2059
13 83 32

(for Equifax's most up-to-date contact details please visit their website at www.equifax.com.au)

Opting out of direct marketing pre-screenings
A CRB may use your credit reporting information to assist a credit provider to market to you by pre-screening you for direct marketing by the credit provider. This process is known as a "pre-screening". If you do not want any of the CRBs listed above to use your information for the purpose of pre-screening, you have the right under the Privacy Act to request that they exclude you by contacting them.

If you are a victim of fraud (including identity-related fraud)
You are entitled under the Privacy Act to request that a CRB not use or disclose credit reporting information they hold about you in circumstances where you reasonably believe that you have been or are likely to be a victim of fraud, including identity-related fraud. The period while this applies is called a "ban period". You can make such a request to any of the CRBs listed above.

We may as permitted by law also share credit information with third parties, including:

• other credit providers;

• our related companies;

• organisations that perform credit assessment, management and debt collection activities on our behalf;

• current or prospective guarantors or security providers in relation to credit we are providing to you;

• mortgage insurers;

• other companies that we partner with to provide products and services, and their service providers;

• external dispute resolution schemes (for example, the Australian Financial Claims Authority); and

• organisations involved in debt assignment or securitisation arrangements.

(In some circumstances we may require your consent before being able to make such disclosures).

Some of these recipients may be located outside Australia.

You are entitled under the Privacy Act to access the credit information we hold about you (in a manner you request, if this is reasonable and practicable). You can make the request in a letter or by telephone if you prefer. To make such a request please see our Credit Corrections Team contact details below.

By telephone

Billfix: 07 55188217

In writing
Credit Corrections
PO Box 4210, Nerang QLD 4211

We will need to validate the identity of anyone making an access request, to ensure that we do not provide your information to anyone who does not have the right to that information.

If you are seeking information on another person's behalf, we will require authorisation from that Individual.

We will usually provide you with access within 30 days of a request but in some circumstances it may take longer.

Your rights to access your credit information are subject to some limitations (for example, we do not have to provide you with access to the extent it would be illegal to do so and we may need to give you access in a way that preserves the confidentiality of any methodology, data analysis methods, computer programs or other information used by us to derive relevant information).

If access is refused, we will give you a notice explaining our decision to the extent practicable and your options.

There is no charge for making an access request but an administration charge may apply for providing access in accordance with your request.

If you believe that any credit information held by us about you is not accurate, complete or up to date, you have the right under the Privacy Act to request that we correct that information.

If you would like to do so please contact the Credit Corrections Team using the contact details above.

If you are seeking to correct information on another person's behalf, we will require authorisation from that Individual.

We will normally try to resolve correction requests within 30 days of your making a request. If we need more time to resolve your request, we will notify you in writing as to the delay and seek your agreement to a longer period. If we consider it  necessary in order to deal with your request, we may consult with a CRB or another credit provider.

If we do not agree with a request to correct credit information we hold about you we will give you notice in writing as to our reasons and the mechanisms available to you to complain about our decision.

There is no cost involved for you to make a correction request or for the correction of your information.

If an issue has not been resolved to your satisfaction, you can lodge a complaint with the Australian Financial Complaints Authority, or AFCA. AFCA provides fair and independent financial services complaint resolution that is free to consumers.

 

Website:  www.afca.org.au

Email:      info@afca.org.au

Telephone:              1 800 931 678 (free call)

In writing to:            Australian Financial Complaints Authority

GPO Box 3, Melbourne VIC 3001

If you wish to find out more information, or raise any specific or general concerns, about our Credit Reporting Policy or credit reporting practices, our contact details are as follows:

By telephone

Billfix: 07 55188217

In writing

Privacy Officer
PO Box 1042, Nerang QLD 4211

Please do not include account numbers or other sensitive data in emails, since it may not be secure.