• ‘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’);
• ‘Disclosure’ of information means providing information to persons outside Fundo Loans
• ‘Individual’ means all persons whose personal information we collect, use or disclose.
• ‘Personal information’ means information or an opinion relating to an individual, which can be used to identify that individual;
• ‘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;
• ‘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;
• ‘Third Parties’ mean customers, suppliers, sub-contractors, agents or other people having a commercial relationship with Fundo Loans and
• ‘Use’ of information means use of information within Fundo Loans.

• Name
• Address
• Phone numbers
• Employment details and pay slips
• Bank account details and account statements/li>
• Drivers’ licence details
• Marital status and dependents
• Financial and credit information, including: details of assets, liabilities, income, expenses
  • 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;
  • information about your repayment history, such as whether you were late in making a monthly repayment and when repayments were due;
  • the type and amount of credit you have applied for;
  • whether you are 60 days or more overdue in making a repayment of $150 or more;
  • whether you have repaid overdue amounts;
  • information about new credit arrangements you have entered into as a result of defaulting on repayments;
  • information about court judgements against you in relation to credit that has been provided to you;
  • 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;
  • any other personal information that may impact our assessment of your credit-worthiness; and
• Any other information that is relevant to the services that we provide.

WHY DO WE COLLECT AND HOLD PERSONAL INFORMATION?

We may collect and hold personal information about you to:

• Assist us in providing you with credit;
• Verify your identity and financial situation;
• Assess whether our credit products are suitable for you;
• Assess any applications by you for credit;
• Managing credit provided to you or collect overdue payments from you;
• Provide you with our promotional material;
• Protect our business and other customers from fraudulent or unlawful activity;
• Conduct our business and perform other management and administration tasks;
• Bring, defend, or manage any legal action involving you and Fundo Loans
• Comply with relevant laws, regulations and other legal obligations, including the National Consumer Credit Protection Act 2009; and
• Help us improve our products and services, and to enhance our overall business.

HOW MIGHT WE USE AND DISCLOSE PERSONAL INFORMATION?

We may use and disclose your personal information for:

• The primary purpose for which it is collected of providing you with credit and managing your loan;
• 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
• 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:

• A related entity of Initium Investments
• 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;
• Organisations involved in a transfer or sale of all or part of our assets or business;
• Organisations involved in managing our payments, payment merchants and other financial institutions such as banks;
• Regulatory bodies, government agencies, law enforcement bodies and courts;
• An individual’s financial institutions, referee(s), employer, co-account holder or authorized signatory; and
• 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:

• Assessing an application by you for credit;
• Collecting payments that are overdue in relation to credit provided by us;
• Dealing with a serious credit infringement we believe you have committed;
• Responding to questions in the course of an investigation by AFCA, or any other external dispute resolution body of which we are a member;
• Purposes required or authorised by law;
• Assisting you to avoid defaulting on your obligations; or
• Internal management purposes that are directly related to the provision or management of credit to you.
• A related body corporate;
• A person who will be processing your application for credit;
• A person who manages credit provided by us for use in managing that credit;
• 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:

• We have taken reasonable steps to ensure the recipient does not breach the Act, the APPs and the Credit Reporting Privacy Code;
• 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:

• Data ownership is clearly defined within this policy
• Passwords are routinely checked;
• We change employees’ access capabilities when they are assigned to a new position;
• Employees have restricted access to certain sections of the system;
• The system automatically logs and reviews all unauthorized access attempts;
• The system automatically limits the amount of personal information appearing on any one screen;
• Unauthorized employees are barred from updating and editing personal information;
• All personal computers which contain personal information are secured, physically and electronically;
• Data is encrypted during transmission over the network;
• Print reporting of data containing personal information is limited;
• Fundo Loans has created procedures for the disposal of personal information; and
• 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:

• The personal information does not include sensitive information; and
• You would reasonably expect us to use or disclose the information for the purpose of direct marketing; and
• We provide you with a simple way of opting out of direct marketing; and
• 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:

• Telephoning us on 02 91387875
• Writing to: The Privacy Officer , at 100 Harris Street Pyrmont NSW 2009
• Emailing hello@fundo.com.au

If you are not satisfied with the response to your complaint you can contact:

• Australian Financial Complaints Authority (AFCA) CAN BE CONTACTED AT 1800 931 678, www.afca.org.au OR PO BOX 3, Melbourne, VIC 3001; or
• The Office of the Australian Information Commissioner by calling 1300 363 992, emailing enquiries@oaic.gov.au, or
• Writing to Director of Complaints, Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001.