CREDITSME Privacy Policy - Version 1 FEBRUARY 2016

1. INTRODUCTION

CreditSME Pty Ltd ACN 608 687 452 and each of its Related Bodies Corporate (referred to as 'we', 'our', 'us') recognise the importance of ensuring the confidentiality and security of your personal information and have developed this Privacy Policy.

This policy is current as at February 2016 and may be updated by us. We will publish our most recent version of this policy at www.creditsme.com.au/legal/privacy and encourage you to periodically review this page for the latest information on our Privacy Policy. When we make changes to this Privacy Policy we will revise the revision date at the top of the Privacy Policy.

Copies of this Policy are available free of charge by contacting our Privacy Officer or can be downloaded from our website www.creditsme.com.au.

This Privacy Policy only applies to information relating to individuals.

2. DEFINITIONS

In this Privacy Policy terms have the following meaning:

APPs	Australian Privacy Principles;
Disclosing	providing information to persons outside of us;
Personal information	information or an opinion relating to an individual, which can be used to identify that individual;
Privacy Act	Privacy Act 1988 (Cth);
Privacy Officer	the contact person for questions or complaints regarding our handling of personal information;
Relates Bodies Corporate	has the meaning given in the Corporations Act 2001 (Cth):
Sensitive information	personal information that includes information relating to a person's racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, and also includes health information;
Use	means our use of information

 

3. WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?

We may collect and hold a range of information about you that is reasonably necessary for, or directly related to, one or more of our functions or activities, including:

a) non-public, personal information you knowingly choose to disclose, which is collected on an individual basis via internet, fax, phone, or mail, If you choose to correspond through e-mail, we may retain the content of your e-mail messages together with your e-mail address and all responses sent through our website;

b) website use information collected on an aggregate basis as you and others users our website;

c) information regarding applications for credit, credit liabilities, repayment history, payment history, defaults, court proceedings and insolvency;

d) information from credit bureaus and small business databases;

e) details about your activity on selected online webpages;

f) information we obtain to verify representations made by you, such as your passport, medicare card, bank account details, as well as business details (such as name, ABN, address);

g) information about you and your business from public sources and other third party affiliated and non-affilated sources; and

h) details about specific transactions conducted in the course of your business.

 

4. HOW DO WE COLLECT PERSONAL INFORMATION?

We generally collect personal information directly from you (through for example our application process, forms, website and other correspondence) such information may include your name, contact details and products you may be interested in.

We may also collect personal information about you from third parties, including, but not limited to:

a) banks and non-bank financial institutions, lenders, credit agencies, credit providers, credit reporting bodies, governmental agencies, marketing agencies;

b) our Related Bodies Corporate;

c) consultants who analyse traffic at our website, which may involve the use of cookies (see section ); and

d) third party accountants or advisors, with your consent.

We will not collect sensitive information about you without your consent unless an exemption in the APPs applies. These exceptions include if the collection is required or authorised by law or necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.

Your failure to provide us with the personal information we request may mean we:

· are unable to provide our services to you or your business;

· can provide only a reduced service; or

· decide to provide our services on terms that are less favourable to you or your business.

 

5. WHO DO WE COLLECT PERSONAL INFORMATION ABOUT?

The personal information we may collect and hold includes (but is not limited to) personal information about the following individuals:

a) customers;

b) potential customers;

c) visitors to our website; and

d) credit providers, consultants or service providers.

 

6. USE OF PERSONAL INFORMATION?

We collect and hold personal information about you so that we may:

a) provide you with our products and services;

b) review and meet your ongoing needs;

c) provide you with information we believe may be relevant or of interest to you including about other products and services we offer, special offers or events;

d) consider any concerns or complaints you may have;

e) comply with relevant laws, regulations and other legal obligations; and

f) help us improve the products and services we offer.

We may use and disclose your personal information for any of these purposes. We may also use and disclose your personal information for secondary purposes which are related to the primary purposes set out above, or in other circumstances authorised by the Privacy Act.

Sensitive information will be used and disclosed only for the purpose for which it was provided, unless you agree otherwise or an exemption in the Privacy Act applies.

7. WHO DO WE DISCLOSE PERSONAL INFORMATION TO?

Unless expressly specified with regard to specific information that we collect from your, we may disclose personal information to:

a) our Related Entities or Related Bodies Corporate;

b) agent, professional advisor or service provider we engage to carry out our functions and activities (such as, but not limited to, lawyers, accountants, IT contractors, marketing companies;

c) organisations involved in a transfer or sale of our assets or business;

d) financial institutions involved in managing our payments, such as banks:

e) regulatory bodies, government agencies, law enforcement bodies and courts; and

f) anyone to whom you authorise us to disclose it. Where you elect to purchase a package that includes a service of matching your company to the most appropriate financiers, you authorize us to disclose your information to the financiers which we identify as most appropriate to your business.

If we disclose your personal information to service providers that perform business activities for us, they may only use your personal information for the specific purpose for which we supply it. We will ensure that all contractual arrangements with third parties adequately address privacy issues and will make third parties aware of this Policy.

8. CREDIT REPORTING BODY

We may collect, hold and use, information related to your commercial and consumer creditworthiness from third party information providers, including credit reporting bodies, for all purposes permitted by law.

9. MANAGEMENT OF PERSONAL INFORMATION

We recognise the importance of securing the personal information of our customers. We will take steps to ensure your personal information is protected from misuse, interference or loss, and unauthorised access, modification or disclosure.

Your personal information (other than credit card numbers) is generally stored in our computer database. Any paper files are stored in secure areas. In relation to information that is held on our computer database, we apply the following guidelines:

a) passwords are required to access the system

b) employees have restricted access to certain sections of the system;

c) the system automatically logs and reviews all unauthorised access attempts;

d) unauthorised employees are barred from updating and editing personal information;

e) all computers which contain personal information are secured both physically and electronically; and

f) print reporting of data containing personal information is limited.

When you enter credit card numbers on our website we encrypt that information using secure socket layer technology. When collected credit card details are simply passed on in order to be processed as required. We never permanently store complete credit card details.

We will exercise reasonable care in providing secure transmission of information between your computer and our servers, but given that no information transmitted over the Internet can be guaranteed 100% secure, we cannot ensure or warrant the security of any information transmitted to us over the Internet and hence accept no liability for any unintentional disclosure. For further information, please see our Terms of Use.

In the event there is a data breach, we will notify you within 45 days and include details of:

· what type of information was breached;

· when the breach occurred;

· what steps you can follow to further protect your information;

· what actions we are taking regarding the breach and to ensure the breach does not happen again.

10. DIRECT MARKETING

We may only use personal information we collect from you for the purposes of direct marketing without your consent if:

a) the personal information does not include sensitive information; and

c) we provide a simple way of opting out of direct marketing; and

d) you have not requested to opt out of receiving direct marketing from us.

If we collect personal information about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent) and we will be given the opportunity to opt out of receiving direct marketing from us.

You have the right to request us not to use or disclose your personal information for direct marketing purposes.

 

11. Choice/Opt-Out

You may choose to stop receiving our marketing emails by following the unsubscribe instruction included in these emails or you can contact us at privacy@creditsme.com.au.

We reserve the right to send you certain communications relating to the CreditSME services, such as service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. We may also contact you by telephone or text message in connection with CreditSME's services. If you would rather not receive telephone calls or text messages from us, you may ask to be removed from our contact list by contacting us at privacy@creditsme.com.au.

 

12. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

We will provide you with access to your personal information as required under the Privacy Act but note that we may not always be required to do so (we will provide reasons if that is the case).

We are committed to ensuring that the personal information we collect, hold, use and disclose is relevant, accurate, complete and up-to-date. We encourage you to contact us if any personal information we hold about you needs to be updated. We will not charge you for correcting your personal information.

 

13. OUR RESPONSIBILITIES

It is the responsibility of management to inform employees and other relevant third parties about this Policy and any updates to this Policy. Employees or other relevant third parties that do not comply with this Policy may be subject to disciplinary action.

 

14. COOKIES

Cookies help us collect important business and technical statistics which enable us to serve you better. The information in the cookies lets us track the various paths followed by users of our website as they move from one page to another while on our website. Web server logs allow us assess site visits and site visit capacity. These methods are not used to capture individual e-mail address or any personally identifying information about you.

15. MAKING A COMPLAINT

If you have any questions about this Policy, or wish to make a complaint about how we have handled your personal information, you can contact our Privacy Officer in writing or by email as follows:

Attention: Privacy Officer
CreditSME Pty Ltd
Level 4, 17-19 Bridge Street, Sydney, NSW, 2000

Email: support@creditsme.com.au.

If you are not satisfied with our response to your complaint, you can also refer your complaint to the Office of the Australian Information Commissioner:

Phone:1300 363 992
Address: Director of Complaints
Office of the Australian Information Commissioner
GPO Box 5218
SYDNEY NSW 2001

Email: enquiries@oaic.gov.au.

Contact

If you have any questions relating to these conditions of use, please contact us at support@creditsme.com.au