We are bound by the Privacy Act 1988 (Cth) (Privacy Act) (including the Australian Privacy Principles) and the Privacy (Credit Reporting) Code 2014.
We are committed to safeguarding your privacy; in this policy we explain how we will treat your personal information.
If you do not wish to provide your personal information to us, then you do not have to do so, however it may affect our ability to provide services to you.
2. WHAT TYPES OF INFORMATION DO WE COLLECT AND WHY DO WE COLLECT IT?
We only ask for personal information relevant to our business relationship with you as a customer.
2.1. PERSONAL INFORMATION
Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual who is identified, or who can reasonably be identified, from the information or opinion. When you apply for one of our products or services, we may request personal information including, but not limited to:
- Information which identifies you (such as your name, address and other contact details, your tax file number and your date of birth);
- Information about your financial position (such as your income, expenses, savings and assets and any (other) credit arrangements); and
- Information about your use of our products or services, or those of our related entities.
Your domain name, email address and information on what pages you access when you visit our website; and
- Your employment details;
- Your bank account details;
- Your reasons for applying for a product or service; and
- Information that may be provided to us by a credit reporting body.
2.2. CREDIT INFORMATION
Information collected for credit purposes includes some elements of personal information but also includes the following:
- How you have managed your credit obligations, such as your repayment history;
- Information about you from a credit reporting body;
- Information about court judgments which relate to credit that an individual has obtained or applied for;
- Personal insolvency information, which includes information about any procedures under the Bankruptcy Act 1966 (Cth) which relate to you and can be found on the National Personal Insolvency Index;
- Scores and other information relating to your credit worthiness which is derived by credit reporting bodies wholly or partly on the basis of the information above;
- An opinion of a credit provider that you have seriously failed to meet the requirements of any credit you have borrowed from that credit provider;
- Details of credit (including the name of each relevant credit provider) that you have applied for, the type and amount of that credit and the fact that a credit provider, mortgage insurer or trade insurer has sought information about you from a credit reporting body in relation to an application;
- Payment information, which includes details of the date on which you have paid overdue amounts that were previously recorded as default information with a credit reporting body or serious credit infringements by you; and
- New arrangement information which includes a statement that the terms or conditions of your credit (in relation to which default information or a serious credit infringement has been disclosed to a credit reporting body) have been varied or that you have been provided with new credit.
In some cases, if we do not collect the information we require, then we may be unable to undertake certain activities, such as providing you with credit.
2.3. SENSITIVE INFORMATION
Where it is necessary to do so, we may collect personal information about you that is sensitive information. ‘Sensitive information’ is information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation, criminal record, and health information about an individual.
We will seek your consent before we collect any sensitive information from you, unless we are required or permitted by law to do so.
3.HOW DO WE COLLECT INFORMATION?
3.1. INFORMATION COLLECTED DIRECTLY FROM YOU
Wherever possible, we will collect all information directly from you, generally from the information you provide to us in your application for one of our products or services.
Where we communicate with you over the phone we may record those phone calls for training, quality assurance purposes or to maintain a record of your instructions to us.
We will inform you if you are being recorded, and you have the right to request that we do not record you. Please note if you request that we do not record you, we may not be able to assist you with your query over the phone.
3.2. INFORMATION COLLECTED FROM THIRD-PARTIES
We may also collect personal information about you from third parties, such as any referees that you provide, your employer, a referrer who may have referred you to us for a product or service, other credit providers and third party service providers including credit reporting bodies. Credit reporting bodies collect credit information about individuals and companies, which they provide as credit reports to credit providers (like us) and others in the credit industry to assist them in managing credit risk, collecting debts and other related activities.
We will only collect your personal information and credit related information from third parties if it is unreasonable or impractical to collect the necessary information directly from you or if we are otherwise permitted to do so.
You can also ask a credit reporting body, through contact details on their website, not to use or disclose your personal information if you believe on reasonable grounds that you have been or are likely to be a victim of fraud, including identity fraud.
3.3. INFORMATION COLLECTED THROUGH OUR WEBSITES
When you visit our websites we will sometimes collect information about your visit to help us to improve the experience you have. This will help us improve and maintain the security measures we have in place, or learn more about you so any marketing we provide you is as relevant as possible. Information we collect for these purposes includes but is not limited to:
- The time,date, and length of the visit;
- Personal information;
- Sensitive information;
- Any information or documentation that you download;
- Your browser type;
- Traffic source:
- Device Type
- Page views;
- Heatmap monitoring;
- Usage data;
- What sections of our websites you view and any errors you experience; and
- Internet protocol (IP) details of the device used to access the site.
It is necessary for us to collect your IP address for your interaction with various parts of our website. Your IP address will not be used by us or released to any third party except in the case of security, inappropriate behaviour or fraud issues, such as unauthorised access to your or our computer systems or fraudulent transactions.
Our website also includes a number of calculators, which may require you to enter your personal details. If you save the data you enter on the calculator, this information will be stored. Otherwise, please note that unless you log-on to our secure internet banking platform, or contact us using an online form, your visit and any browsing you do on our website will be completely anonymous.
Sometimes we may use an external service to collect the above information and provide us with reports that help us to understand our website’s traffic and webpage usage.
4. USE OF INFORMATION
We may collect, hold and use your personal information for the purpose of providing products and services to you and managing our business. This may include:
- Assessing and processing your application for the products and services we offer;
- Executing your instructions;
- Charging and billing;
- Uses required or authorised by law;
- Collecting overdue payments due under our credit products;
- Providing and marketing our services to you;
- To identify you and for us and our lenders to conduct know-your-customer checks and communicate with you;
- To monitor usage of our systems and services, to enables us to better understand how our services and resources are being used and to plan our future resource needs;
- To protect you and us from fraud; or
- To respond to any queries or complaints you may have;
- Reporting & analytics;
We may use credit related information that we collect and hold for the purpose of:
- Assessing credit risk and credit worthiness (this will not affect your credit score);
- Establishing and managing our relationship with you;
- Exercising our rights and obligations;
- Performing any administrative operations;
- Collecting payments and other enforcement activities;
- To participate in the credit reporting system and provide information to a credit reporting body as permitted by Part IIIA of the Privacy Act and the Credit Reporting Code;
- To meet legal and regulatory requirements;
- To protect you and us from fraud; and
- To respond to any queries or complaints you may have.
In general, we do not use or disclose your information for a purpose other than:
- As required or permitted by law; or
- Otherwise in accordance with your consent.
We may use your information to provide you with information about products and services, including those of third parties, other We Fund Pty Ltd companies which we consider might be of interest to you.
We may also provide your details to other organisations for specific purposes such as direct marketing, statistical analysis, pre-screening for direct marketing and to better understand our customer groups and profiles.
You may opt out at any time if you no longer wish to receive marketing information or do not wish to receive marketing information through a particular channel, such as email. You can make this request by contacting us or by ‘unsubscribing’ from our email marketing messages, which always includes an unsubscribe option.
4.2. CREDIT DIRECT MARKETING
We may use your information for credit direct marketing.
To do this we ask a credit reporting body to “pre-screen” a list of potential recipients of our direct marketing against our eligibility criteria, to remove recipients that do not meet those criteria.
The credit reporting body cannot use information about your existing loans or repayment history in carrying out its pre-screening and it must destroy its pre-screening assessment once it has given us, or a contractor acting on our behalf, the list of eligible recipients.
If you do not want your credit information used for prescreening by a credit reporting body, you can opt-out by informing that credit reporting body. We may disclose information to or collect information from Equifax Inc. To opt-out or obtain further information about Equifax Inc. you can go to www.equifax.com.au.
5. WHO WE DISCLOSE YOUR INFORMATION TO
We do not permit the personal information we hold to be disclosed to third parties unless:
- we consider it necessary to be disclosed in order for the services provided to you be properly carried out; or
- you have consented (expressly or implicitly) or requested your personal information to be provided to a third party; or
- we are required or permitted by law to provide information to a third party.
Third parties to whom we may disclose personal information to include:
- Other entities owned or controlled by We Fund Pty Ltd;
- Our lenders;
- External service providers and any organisations that are our assignees, agents or contractors providing services to us including but not limited to PDF generators, verification of identity, payment system operators, mailing houses and research consultants;
- Insurance providers, where insurance is provided in connection with our services to you;
- Superannuation funds, where superannuation services are provided to you;
- Other financial institutions, for example, when you apply for a loan from another credit provider and you agree to us providing information;
- Providers of professional services such as Loan Mortgage Insurers, collections agencies, lawyers, debt collectors, accountants;
- State, territory or commonwealth courts or tribunals and government departments or regulatory authorities as required;
- Organisations involved in our funding arrangements – including loan purchasers, investors, advisors, researchers, trustees, rating agencies and financial intermediaries;
- Your representative, for example, a lawyer, mortgage broker, financial advisor or attorney, as authorised by you; or
- The issuer of any documents which you provide us with for the purposes of verifying those documents e.g. to verify a drivers licence with the Australian State or Territory who issued it.
We may disclose certain information about you to credit reporting bodies, for example, if you fail to meet payment obligations. The credit reporting bodies may include such information in reports provided to credit providers to assist them in assessing your credit worthiness. We disclose personal information to the following credit reporting bodies:
Organisations providing professional services to us are required to keep those dealings and personal information provided by us as confidential unless required to disclose such information by statute or law.
In the case of contracted service providers, we may disclose personal information to the contracted service provider and the contracted service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.
6. OVERSEAS DISCLOSURE
We may disclose your personal information overseas, including your credit information to our third party service providers located overseas in Countries that include but are not limited to the United States and Singapore, for them to help us provide services to you. Where we are required to provide your information to other organisations in the provision of services, including but not limited to insurers, lenders’ mortgage insurers or other entities necessary in the provision of our products or services, your personal information may be disclosed by these organisations overseas, including your credit information. Our third party service providers may store or access your personal information overseas.
We are committed to ensuring the security of your personal information we hold. We protect your personal information from misuse, interference, loss and unauthorised access, disclosure and modification including through restricted access and secure offsite/onsite storage.
Depending on the type of information, we will sometimes send information to third-party storage providers to hold and keep secure. Where we send your information to a third party, we will take all reasonable measures to make sure your information is protected.
7.1. PHYSICAL INFORMATION SECURITY
In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
Some of the measures we take to protect the physical information we hold about you include:
- Performing customer identification checks before providing any information;
- Providing training to relevant staff on how to manage customer records and information in accordance with this Policy.
7.2. DIGITAL INFORMATION SECURITY
Some of the things we may do to protect the digital information we hold about you include:
- Using up-to-date security measures on our websites to protect your personal information and your credit information;
We ask you to keep your passwords and personal identification numbers safe, do not write them down, allow anyone to see you enter your details and do not tell anyone what they are.
7.3. INFORMATION WE DID NOT ASK FOR OR NO LONGER NEED
Where we are given information that we did not ask for, If we decide we do need this information, we will keep it securely along with the rest of your information. If we do not need this information, we will take reasonable steps to destroy or de-identify it.
We will take reasonable steps to destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Privacy Act.
As an Australian credit licence holder, we are required by law to retain customer identification and transaction information, which will contain personal information about customers, for up to at least seven years after you cease to be our customer.
7.4. IN THE EVENT OF A DATA BREACH
We are bound by the Privacy Act and are committed to complying with the Notifiable Data Breaches Scheme (NDB) established by the Privacy Amendment (Notifiable Data Breaches) Act 2017.
The NDB requires that where a data breach is likely to result in serious harm to any individuals to whom the information relates, we are required to notify those individuals and the Office of the Australian Information Commissioner (OAIC).
The NDB provides greater protection to the personal information of consumers, greater transparency in the way organisations like us respond to data breaches and give individuals the opportunity to minimise the damage caused by any unauthorised use of their personal information.
8. ACCESS AND CORRECTION
You have the right to request access to the personal information that we hold about you at any time. You also have the right to seek correction of the personal information that we hold about you at any time. These requests can be made by contacting us on the details below.
We will respond to your request for access within 30 calendar days. If we refuse to give you access to any of your information, we will provide you with reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access. You can contact us if you would like to challenge our decision to refuse access.
If we refuse to correct your personal information you have the right to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take such steps that are reasonable in the circumstances to associate that statement with all records containing the relevant information.
We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act. If we cannot provide access to your information, we will generally provide you with the reasons why and the mechanisms to complain about that refusal.
There is no charge for making a request to access your information. However, in some cases, there may be a charge to cover the time we spend locating, compiling and explaining the information you ask for. If there is a charge, we will give you an estimate upfront, and confirm that you wish to proceed.
Or you can call us to request a copy by calling (03) 8840 2488
10. OUR CONTACT DETAILS
We take reasonable steps to make sure that the information that we collect, use or disclose is accurate, complete and up-to-date.
Phone: (03) 8840 2488
Address: Level 5, 9-11 Cremorne Street Cremorne VIC 3121
11. COMPLAINTS & FEEDBACK
We take your feedback seriously and aim to provide simple, easy to use and trustworthy services to our customers. We see your complaint or feedback as an opportunity to not only resolve the matter for you, but as a way to improve the way we do things.
You can advise us of your complaint or provide feedback by:
- calling us – (03) 8840 2488 (between 9:00am and 5:00pm Monday to Friday, except on public holidays);
- using the online form at wefund.com.au;
- emailing us – (firstname.lastname@example.org); or
- writing to us (Complaints & Feedback, Level 5, 9-11 Cremorne St, Cremorne VIC 3121).
11.1. DETAILS OF YOUR COMPLAINT OR FEEDBACK
So that we can resolve your complaint as quickly as possible, it is important that you provide us with as much information as possible. This includes details such as:
- your customer number (if you have been assigned one) and name;
- contact details – preferred contact method; if by phone advise the best times to reach you;
- complaint or feedback information – what is your complaint or feedback about and when did it happen; and
- resolution – how would you like the matter resolved.
We will try our best to resolve the complaint for you on the spot, and in most cases we can. If we can’t we will:
- keep you up to date on our investigation and progress;
- work to resolve your complaint within 21 days of receiving it from you;
- let you know if we need more information or more time to investigate; and
- provide you with final resolution within 45 days – if not we will inform you of the reasons for delay.
If we request further information from you to help us resolve your complaint and you do not respond, we may consider the matter resolved. However, if you provide information at a later date we will reopen the complaint and continue to work on a resolution for you.
11.3. OTHER OPTIONS
If you are not satisfied with our initial response, you can request for your complaint to be reviewed by our External Dispute Resolution Service. We Fund Pty Ltd is a member of the Australian Financial Complaints Authority (AFCA). AFCA is an external dispute resolution body that deal with complaints regarding the financial services industry.
Australian Financial Complaints Authority
Phone: 1800 931 678
Mail: Australian Financial Complaints Authority, GPO Box 3 Melbourne VIC 3001
If you feel that we have not satisfactorily addressed your complaint, you may also make a complaint to the Office of the Australian Information Commissioner who can investigate your complaint. They can be contacted by the privacy hotline 1300 363 992, by visiting www.oaic.gov.au, emailing email@example.com or writing to GPO Box 5218 Sydney NSW 2001.