Privacy Policy
Initium Investments Pty Ltd (trading as “Fundo Loans”)
INTRODUCTION
Initium Investments Pty Ltd ACN 604 639 143, Trading as “Fundo Loans”, ABN 65 604 639 143,(referred to as ‘Fundo Loans’’, ‘we’, ‘our’, ‘us’) is a short term credit provider for people who need a small amount of money for a short time.
We recognize that our success in this business depends on us maintaining the utmost commitment to upholding your privacy rights when collecting, holding, using, or disclosing your personal information. We have established a number of procedures and protocols to help us keep personal information we hold secure, accurate, up-to-date, and complete.
This Policy applies to and covers all of operations and functions of Fundo Loans. All staff and third parties (including suppliers, sub-contractors, or agents) that have access to or use personal information collected and held by Fundo Loans must comply with this Privacy Policy.
This Policy outlines Fundo Loans’s obligations to manage and protect personal information and reflects the requirements of the Australian Privacy Principles (‘APPs’), the Credit Reporting Privacy Code (‘theCode’) and the Privacy Act 1988 (Cth) (“the Privacy Act”). This Policy is available free of charge from our website: www.fundo.com.au/privacy-matters.
This Policy also outlines Fundo Loan’s practices, procedures and systems that ensure compliance with the Privacy Act, APPs and the Code.
WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect personal information about you to:
check_circle ‘Credit information’ is personal information (other than sensitive information) that relates to an individual’s credit history or credit-worthiness, and is further defined in the Privacy Act. Credit information includes information that we have obtained from Third Parties, including individuals, other credit providers and credit reporting bodies (‘CRBs’);
check_circle ‘Disclosure’ of information means providing information to persons outside Fundo Loans
check_circle ‘Individual’ means all persons whose personal information we collect, use or disclose.
check_circle ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
check_circle ‘Privacy Officer’ means the contact person within Fundo Loans for questions regarding Fundo Loan’s Privacy Policy. Contact details are 02 91387875 or email hello@fundo.com.au;
check_circle ‘Sensitive information’ is 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;
check_circle ‘Third Parties’ mean customers, suppliers, sub-contractors, agents or other people having a commercial relationship with Fundo Loans and
check_circle ‘Use’ of information means use of information within Fundo Loans.
WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect personal information about you to:
check_circle Name
check_circle Address
check_circle Phone numbers
check_circle Employment details and pay slips
check_circle Bank account details and account statements
check_circle Drivers’ licence details
check_circle Marital status and dependents
check_circle Financial and credit information, including: details of assets, liabilities, income, expenses
check_circle information about consumer credit liabilities, such as the name of an entity that has provided you with credit, the date of the credit was provided and the maximum amount of credit made available;
check_circle information about your repayment history, such as whether you were late in making a monthly repayment and when repayments were due;
check_circle the type and amount of credit you have applied for;
check_circle whether you are 60 days or more overdue in making a repayment of $150 or more;
check_circle whether you have repaid overdue amounts;
check_circle information about new credit arrangements you have entered into as a result of defaulting on repayments;
check_circle information about court judgements against you in relation to credit that has been provided to you;
check_circle publicly available information that relates to your creditworthiness ; information recorded in the National Personal Insolvency Index about you; our opinion as to whether you have committed a serious credit infringement in relation to consumer credit we provided to you;
check_circle any other personal information that may impact our assessment of your credit-worthiness; and
check_circle Any other information that is relevant to the services that we provide.
HOW WE COLLECT PERSONAL INFORMATION
We generally collect personal information directly from you, the individual. For example, we collect your personal information when you inquire about or apply for credit, or contact us about your loan, including when you visit our website, call us or send us correspondence. Sometimes we may need to collect personal information about an individual from a third-party, such as financial institutions, other credit providers, electronic verification services or a CRB. We may collect personal information about you when a person you hold a bank account with gives us information about that account.
When we are provided with personal information from a third-party, we will take reasonable steps to ensure that you are made aware of the matters set out in this Privacy Policy. Fundo Loans will not collect your sensitive information unless you have consented or an exemption under the APPs applies.
These exceptions include if the collection is required or authorized by law or are necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct. If the personal information were quest is not provided, we may not be able to process your application for credit, or meet your needs appropriately.
Fundo Loans does not give you the option of dealing with it anonymously, or under a pseudonym. This is because it is impractical, and in some circumstances illegal, for us to deal with individuals who are not identified.
HOW WE COLLECT PERSONAL INFORMATION
Fundo Loans may receive unsolicited personal information about you. We destroy or de-identify all unsolicited personal information, unless it is relevant to our purposes, under this Policy, for collecting personal information.
WEBSITE COLLECTION
We collect personal information from our website www.fundo.com.au we receive emails and online account application forms. We may also use third parties to analyse traffic at that website, which may involve the use of cookies. Information collected through such analysis is anonymous.
WHY DO WE COLLECT AND HOLD PERSONAL INFORMATION?
We may collect and hold personal information about you to:
check_circle Assist us in providing you with credit;
check_circle Verify your identity and financial situation;
check_circle Assess whether our credit products are suitable for you;
check_circle Assess any applications by you for credit;
check_circle Managing credit provided to you or collect overdue payments from you;
check_circle Provide you with our promotional material;
check_circle Protect our business and other customers from fraudulent or unlawful activity;
check_circle Conduct our business and perform other management and administration tasks;
check_circle Bring, defend, or manage any legal action involving you and Fundo Loans
check_circle Comply with relevant laws, regulations and other legal obligations, including the National Consumer Credit Protection Act 2009; and
check_circle Help us improve our products and services, and to enhance our overall business.
HOW MIGHT WE USE AND DISCLOSE PERSONAL INFORMATION?
check_circle The primary purpose for which it is collected of providing you with credit and managing your loan;
check_circle Secondary purposes which are related to this primary purpose that you may reasonably expect, such as keeping you informed about changes to your loan, or new products and services; and
check_circle Other purposes authorized by the Privacy Act.
We use and disclose personal information for the purposes outlined in section 6 above. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or if certain other limited circumstances apply (e.g., where required by law). Credit information will only be used and disclosed for the purposes outlined in section 9 below.
We engage other people to perform services for us (“contractors”), which may involve them handling personal information we hold. In these situations, we prohibit contractors from using personal information about you except for the specific purpose for which we supply it. We prohibit contractors from using your information for the direct marketing of their products or services.
Fundo Loans will attempt to de-identify sensitive information held by us, wherever possible. We also undertake to delete all personal information about you when it is no longer needed or relevant.
TO WHOM MIGHT WE DISCLOSE PERSONAL INFORMATION?
We may disclose your personal information, excluding credit information, to:
check_circle A related entity of Initium Investments
check_circle An agent, contractor or service provider we engage to carry out functions and activities in connection with approving or administering credit products or services, such as our electronic verification service, lawyers, accountants, debt collectors or other advisors;
check_circle Organisations involved in a transfer or sale of all or part of our assets or business;
check_circle Organisations involved in managing our payments, payment merchants and other financial institutions such as banks;
check_circle Regulatory bodies, government agencies, law enforcement bodies and courts;
check_circle An individual’s financial institutions, referee(s), employer, co-account holder or authorized signatory; and
check_circle Anyone else to whom the individual authorises us to disclose it.
HOW MIGHT WE USE AND DISCLOSE CREDIT INFORMATION?
We will only use and disclose your credit information for the following purposes:
check_circle Assessing an application by you for credit;
check_circle Collecting payments that are overdue in relation to credit provided by us;
check_circle Dealing with a serious credit infringement we believe you have committed;
check_circle Organisations involved in managing our payments, payment merchants and other financial institutions such as banks;
check_circle Responding to questions in the course of an investigation by AFCA, or any other external dispute resolution body of which we are a member;
check_circle Purposes required or authorised by law;
check_circle Assisting you to avoid defaulting on your obligations; or
check_circle Internal management purposes that are directly related to the provision or management of credit to you.
check_circle A related body corporate; or
check_circle A person who will be processing your application for credit; or
check_circle A person who manages credit provided by us for use in managing that credit;
check_circle Another credit provider if we believe you have committed a serious credit infringement, or the individual has consented to the disclosure; to a debt collector; or a CRB.
If we intend to provide default information about an individual to a CRB, we will give you at least 14 days’ written notice. If we disclose default information to a CRB, and you subsequently repay the amount owed, we will tell the CRB that you have repaid the amount owing. We will not disclose credit repayment history information to the CRB which is more than 2 years old or relates to an amount owing of less than $150.
SENDING INFORMATION OVERSEAS
We will not send personal information to recipients outside of Australia unless:
check_circle We have taken reasonable steps to ensure the recipient does not breach the Act, the APPs and the Credit Reporting Privacy Code;
check_circle The recipient is subject to an information privacy scheme similar to the Privacy Act; or the individual has consented to the disclosure.
MANAGEMENT OF PERSONAL INFORMATION
The APPs require us to take all reasonable steps to protect the security of personal information, including credit information. Fundo Loans employees respect the confidentiality of the personal information we collect.
We take reasonable steps to protect personal information held from misuse, loss, unauthorized access, modification or disclosure. All personal information contained in hard copy documents held by us is stored in locked cabinets. All personal information stored on Fundo Loan’s computer system is backed up regularly, and back-up copies are held in a secure location. In relation to our customer database, we apply the following guidelines:
check_circle Data ownership is clearly defined within this policy
check_circle Passwords are routinely checked;
check_circle We change employees’ access capabilities when they are assigned to a new position;
check_circle Employees have restricted access to certain sections of the system;
check_circle The system automatically logs and reviews all unauthorized access attempts;
check_circle The system automatically limits the amount of personal information appearing on any one screen;
check_circle Unauthorized employees are barred from updating and editing personal information;
check_circle All personal computers which contain personal information are secured, physically and electronically;
check_circle Data is encrypted during transmission over the network;
check_circle Print reporting of data containing personal information is limited;
check_circle Fundo Loans has created procedures for the disposal of personal information; and
check_circle Personal information is overwritten to the extent possible when the information is no longer required.
Where we no longer require personal information we will take reasonable steps to destroy or de-identify it.
DIRECT MARKETING
Fundo Loans does not use your personal information for the purposes of direct marketing, unless:
check_circle The personal information does not include sensitive information; and
check_circle You would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
check_circle We provide you with a simple way of opting out of direct marketing; and
check_circle You have not requested to opt out from receiving direct marketing from us.
If you would not reasonably expect us to use or disclose the information for the purpose of direct marketing, we may only use or disclose that information for direct marketing if you have consented to the use or disclosure of the information for direct marketing or it is impracticable to obtain that consent.
Individuals can opt out of direct marketing by contacting us, and we will give effect to the request within a reasonable period of time. Fundo Loans will provide you with the source of its information about you on request free of charge within a reasonable period of time.
We will not use or disclose credit information for the purposes of direct marketing.
Fundo Loans may only use or disclose sensitive information about you for the purpose of direct marketing with your consent.
IDENTIFIERS
We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes, unless one of the exemptions in the Privacy Act applies. Fundo Loans endeavours to avoid data-matching.
HOW DO WE KEEP PERSONAL INFORMATION ACCURATE AND UP-TO-DATE?
Fundo Loans takes reasonable steps to ensure that the personal information, including credit information, it collects, uses and discloses is relevant, accurate, complete and up-to-date.
We encourage you to contact us in order to update any personal information we hold about you. If we correct information that has previously been disclosed to another entity, we will notify the other entity within a reasonable period of the correction. If we are satisfied that personal information we hold is inaccurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. We do not charge you for correcting your information.
ACCESS TO PERSONAL INFORMATION
Subject to the exceptions set out in the Privacy Act, you may gain access to the personal information, including credit information, which Fundo Loans holds about you by contacting the Fundo Loans Privacy Officer. We will provide access within 30-days of the individual’s request. If we refuse to provide access, we will provide reasons for the refusal.
You can look at your personal information at the offices of Fundo Loans. We will require you to verify your identity and specify what information is required. An administrative fee for search and photocopying costs may be charged for providing access.
UPDATES TO THIS POLICY
This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and the business environment. You will be notified if that happens.
INQUIRIES AND COMPLAINTS
If you have any questions about our privacy procedures, or if you wish to make a complaint about how we have handled your personal information (including credit information) you may lodge a complaint by:
check_circle Telephoning us on 02 91387875
check_circle Writing to: The Privacy Officer , at 13 38-46 South Street Rydalmere NSW 2116 Australia
check_circle Emailing hello@fundo.com.au
If you are not satisfied with the response to your complaint you can contact:
check_circle Australian Financial Complaints Authority (AFCA) CAN BE CONTACTED AT 1800 931 678, www.afca.org.au OR PO BOX 3, Melbourne, VIC 3001; or
check_circle Writing to: The Office of the Australian Information Commissioner by calling 1300 363 992, emailing enquiries@oaic.gov.au, or
check_circle Writing to Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001.
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