This policy is effective immediately, and will be reviewed when necessary.
The Privacy Officer has the primary responsibility for performance of the duties under this policy.
Personal information means 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 material form or not.
The personal information we collect will depend upon the purposes for which it is collected. When an individual applies for a product or service, we will collect the information we consider is or may be necessary to enable us to assess the application, to provide the product or service, and to administer the product or service after it has been provided.
Examples of personal information collected by emoney include name, date of birth, current and previous residential addresses, telephone number, email address, employer, place of work, occupation, business experience, income, assets, liabilities, credit history and other financial and credit-related information. We may also collect driver’s licence number, passport number or other identification information provided in connection with an application (including 100 point check or identification reference) for emoney to establish your identity and the identity of signatories to accounts.
We may collect credit-reporting information about individual loan applicants or guarantors. We always obtain written consent before doing this. The types of credit reporting information that may be provided to emoney by credit reporting bodies include:
Personal information can include sensitive information. Sensitive information is defined in the Privacy Act as information or an opinion about a person’s race, ethnic origin, political opinions, membership of political associations and trade associations, religious or philosophical beliefs, sexual orientation or practices, or criminal record, health information, genetic information about an individual that is not otherwise health information, biometric information that is used for the purpose of automated biometric verification or biometric identification and biometric templates.
emoney may collect health information, information about membership of political associations and trade association and criminal records, where required for our business purposes. Where health details or other sensitive information is required in order for us to provide a product or service, it will not be used for any other purpose than that for which it was collected.
emoney does not usually request tax file numbers except if required for purposes authorised by taxation law, such as for the provision of Annual Investment Reports to the Australian Taxation Office. If tax file numbers are otherwise inadvertently provided with loan application documentation, they are redacted from the relevant documents by our staff.
We will generally collect the personal information we need about an individual directly from that individual whenever it is reasonable and practicable to do so (e.g. face-to-face, telephone or through completion of forms). We may do so when:
We may also obtain personal information (including credit-related information) about an individual who is seeking credit or who has offered to be a guarantor, from third parties including:
If an individual is seeking credit, we may contact the individual’s employer to confirm that the employer employs the individual.
Entities we may disclose personal information to in the course of our business include:
We only collect personal information if it is reasonably necessary for one or more of our business functions or activities.
The purposes for which emoney collects, holds, uses and discloses personal information include opening of accounts (including identity verification requirements), assessing and actioning credit applications, loan account management, providing or managing other products and services including securitisation of loans, effecting transactions authorised by you, account administration, planning, product research and development, other internal management functions and operations related to the provision or management of products by emoney, management of our business, enhancing emoney’s relationship with you, seeking credit information from credit reporting bodies such as Equifax Group, DNB and Experian, debt collection, complying with our legal obligations, audit, assessment of employment applications and to provide information required by law for employment purposes.
We never sell or disclose any personal information to third parties for direct marketing by other organisations.
We never use sensitive information or credit eligibility information for direct marketing purposes without that individual’s consent.
This section provides more information about how we deal with credit-related information. Credit reporting information is only sought by emoney with the written consent of the individual borrower or guarantor concerned.
emoney may provide the following types of credit information to credit reporting bodies with a request for credit reporting information:
emoney may use and disclose credit information and credit eligibility information, as well as other information provided by borrowers and guarantors, as follows:
The kinds of information emoney may derive from credit reporting information obtained from Equifax Group, DNB and Experian includes an opinion about your eligibility for credit.
Credit eligibility information will be held and used in accordance with Part IIIA of the Privacy Act 1988 (Cth), this policy, and the terms of the consent provided by the relevant individuals.
emoney is not likely to disclose any credit information or credit eligibility information to entities that do not have an Australian link.
We do not use any government related identifiers, such as driver’s licence numbers, as its own internal identifier of any individual. We will not use or disclose any government related identifiers other than in accordance with the Privacy Act 1988 (Cth).
emoney tries to ensure that all personal information it holds is accurate, complete and up-to-date. To assist us with this, individuals should contact us if any of their personal information changes, or if they believe that the personal information we have is not accurate or complete.
emoney takes reasonable steps to protect the personal information that it holds from misuse, interference or loss, or from unauthorised access, modification or disclosure. If emoney no longer requires personal information that it holds, it will take such steps as are reasonable in the circumstances to destroy the information or ensure that the information is de-identified.
The Insurers and Credit Providers may disclose your personal and credit information overseas, including in the United States of America, The European Union, Canada, India, Malaysia, Philippines, Asia Pacific, New Zealand and United Kingdom. More information on overseas disclosure may be found in the relevant entities’ privacy policies.
We may, or an Insurer may, store your information in cloud or other types of networked or electronic storage and will take reasonable steps to ensure its security, however, it is not always practicable to find out where your information may be accessed or held, as electronic or networked storage can be accessed from various countries via an internet connection.
We have a contract in place that requires our service provider to only deal with the personal information for the purpose of providing services to emoney, and to observe the Australian Privacy Principles when handling any personal information that we disclose to them. Under our contract, the service provider is not permitted to disclose that personal information to any sub-contractors or other third parties.
We are otherwise unlikely to disclose your personal information to overseas recipients, however if we do so, it will be in accordance with the Privacy Act 1988 (Cth).
Individuals can ask emoney for access to their personal information held by emoney (including credit related information) by sending a written request to our Privacy Officer at firstname.lastname@example.org. The request must identify the individual and, with reasonable particularity, the information required.
emoney does not impose a charge for making a request for access, however we may charge for reasonable administrative costs incurred in providing access.
An individual can ask emoney to correct or update that individual’s personal information (including credit related information). emoney does not impose any charge with respect to requests for correction or updates.
Before correcting or providing access to personal information in response to a request, emoney will require the individual’s identity to be confirmed.
Requests for access or correction may be refused upon the grounds contained in the Privacy Act 1988 (Cth). If we refuse to provide access, or to correct personal information, we will provide reasons for the refusal.
emoney will respond to an individual’s request for access as soon as reasonably practicable, taking into account the age, nature and amount of the information requested.
Individuals have the right to request a copy of the credit information that credit providers hold about them and to have the credit information corrected if it is inaccurate.
If you visit our website, certain information can be collected.
If you visit the emoney website, our internet service provider can record certain information about your visit, including:
This information is only used for statistical and website development purposes, and does not personally identify you.
emoney may also collect names, email addresses and contact telephone numbers from enquiries sent to our website. These contact details will not be provided to any third parties. Any emails sent to us and our responses will be saved if we consider it necessary to do so.
In order to protect your personal information, any data transmitted via the internet containing your personal information is encrypted. Other security measures are also implemented. However, we cannot guarantee that any personal information, which we transmit via the internet, is completely secure.
We also enter into contracts with service providers overseas who provide services to us or who provide products or services jointly with us. These contracts require the service providers to meet the privacy standards we set for ourselves in protecting your personal information and comply with the Privacy Act. The personal information is used only for the specific service we ask them to perform or the product/service that we ask them to provide, and for no other purpose.
Under the Privacy Act 1988 (Cth) we are required to advise you of the main consequences (if any) if all or some of your information is not collected by emoney. In the context of our website, the consequence of you not providing us with your personal information is that we may not be able to initiate contact with you.
The use of our website is at your own risk.
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