We understand the importance that you place on your personal information, and are committed to its protection in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (the Act), the Notifiable Data Breach scheme established under the Act, and any other relevant laws relating to personal information. This document also contains a statement of ‘notifiable matters’, in compliance with the Privacy (Credit Reporting) Code 2014 (the Code) issued under the Act.
This Website Policy sets out how we at Rawson Group Pty Limited ACN 000 382 329 and our related entities (Mint, we, us or our) collect, use, manage, and store personal information in connection with the website www.mintloans.com.au (Website).
2. The personal information we collect
2.1 When we use the term “personal information”, we mean any information or opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information or opinion is true, and whether or not the information or opinion is recorded in a material form.
2.2 Credit information is a subset of personal information. That information may be used in an application for finance, and to assess your eligibility to be provided with finance.
2.3 The personal information that we may collect or hold will depend on the context in which we collect it, and may include:
- your name, date of birth and contact details including address, email address and phone number (including mobile telephone number);
- employment information (including company name and position);
- your financial information (including expenditure habits);
- internet protocol (IP) addresses;
- credit information,
and any other personal information you submit to us, as well as any other information that we consider is necessary to perform our services.
3. How personal information is collected
3.1 We collect personal information in a number of ways, including:
- from you directly, for instance when you provide information on a hard copy form, by email, by phone, in person, by live chat, or when you submit your personal details through our Website or our online forms;
- from our own records;
- from third parties, such as our service providers, credit providers, and credit reporting agencies;
- through marketing and business development events;
- from social media platforms (where you have given your consent to their sharing that information with us); and
- from publicly available sources of information.
3.4 Where we lodge an application for finance for you with a credit provider or a financial aggregator, if it is likely that they will disclose that information to a credit reporting body (as described in the Code):
- the credit reporting body may include the information in reports provided to credit providers to assist them to assess your credit worthiness;
- if you fail to meet your payment obligations in relation to consumer credit or commit a serious credit infringement, the credit provider may be entitled to disclose this to the credit reporting body;
- you may obtain the credit provider’s policy about the management of credit-related personal information required by Section 21B of the Act, and the credit reporting body’s policy about the management of credit-related personal information required by Section 20B of the Act, by asking the credit provider/finance aggregator;
- you will have a right to access the information from the credit provider/finance aggregator, to ask them to correct any information that is inaccurate, and to make a complaint to them;
- you will have a right to request credit reporting bodies not to use credit reporting information about you for the purposes of pre- screening of direct marketing by a credit provider; and
- you will have a right to request that the credit reporting body not use or disclose credit reporting information about you, if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud.
The credit provider or finance aggregator will provide you with details as to how to do so, and any issues relating to these matters will be between yourself and them.
3.5 If you choose not to provide certain information about you, we may not be able to provide you with the products or services you require.
3.6 If, at any time, you provide personal information or other information about someone other than yourself, you warrant that you have that person’s consent to provide such information for the purpose specified in this Policy.
4. Purpose of collection, use and disclosure of personal information
4.1 We collect, use and disclose personal information for the primary purpose of conducting our business, which includes:
- verifying your identity;
- providing you with products and services;
- assisting you in your application to a credit provider or finance aggregator or insurer to gain approval for a financial product or service provided by or through them;
- administering our products and services;
- developing and improving our Website and our service and product offerings;
- contacting you in any way (including mail, email, phone, visit, text or multimedia messages) about products and services we offer, and direct marketing to you (see paragraph 9 below);
- responding to your queries or complaints;
- complying with any legal obligations that we may have under laws that apply to our business; and
- any other matters that may reasonably be expected in connection with the above matters, where we have obtained consent for other collection activities, or are otherwise required to do so by law.
4.2 In general, the primary principle is that we will not use any personal information other than for the above purposes or the purpose for which it was collected, except with the individual’s permission or as otherwise permitted by law
4.3 In conducting our operations, we may share some of your personal information with third parties such as:
- credit providers and credit reporting bodies (for credit related purposes such as credit-worthiness checking, credit rating, credit provision and financing);
- government and regulatory authorities and other organisations, as required or authorised by law; and
- our related companies, and our or their outsourced service providers and contractors.
4.4 Except to the extent foreshadowed under this Policy, we will not disclose or sell an individual’s personal information to unrelated third parties.
4.5 We may use aggregated de-identified information that is derived from personal information (aggregated data), including statistical and trend data for any purpose. Before doing so we will ensure that no individual can be identified from such aggregated data.
5. Overseas disclosure
5.1 From time to time, we may disclose your personal information to overseas recipients if it is necessary to provide our services. We also use technology providers that store personal information securely primarily in the United State of America, Switzerland and the EU.
5.2 If we do disclose personal information to an overseas recipient, we take reasonable steps to ensure that the receiving party provides commitments to privacy and confidentiality which are at least equal to the Australian Privacy Principles or the recipient is subject to privacy protection laws that offer at least the same level of protection as required under the Privacy Act 1988 (Cth) in Australia.
6. Storage and security of personal information
6.1 Where we hold your personal information or credit information, we will take reasonable steps to ensure that the information is secure and may only be accessed by authorised persons. For instance, if the personal information is recorded in a physical records (e.g. in printed documents), we will store them in locked cabinets. On completion of your application for finance, we scan those physical records and store them on a server that is protected by reasonable security measures, and destroy the physical files, unless we are obliged to retain them under any law.
6.2 Although we take reasonable measures to secure personal information, we are not responsible for third party circumvention of security measures on our electronic databases or at any of our premises.
6.3 Please note that third party recipients of personal information, including our service providers that provide the information, and credit providers, finance aggregators and insurers to whom we may disclose information as part of the process for applying for finance or other services, may have their own privacy policies and we are not responsible for their actions, including their handling of personal information.
7. Access to and correction of personal information
7.1 We will use reasonable steps to ensure the personal information we hold is complete, up to date and accurate, so far as it is practicable for us to do so. However where you provide or make your personal information available to us, you are responsible for ensuring that what you give us is complete, up to date and accurate
7.2 You may request access to the personal information that we hold about you by contacting our Privacy Officer, using the details set out below. We may, at our discretion, provide you with access to your personal information, and we reserve the right to charge you a reasonable fee for giving access.
7.3 Subject to paragraph 8.4, if personal information that we hold about you is incorrect, then on your request to correct it or where we are satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading, we will take such steps as are reasonable in the circumstances to ensure that the information is corrected.
7.4 If you ask us to correct personal information that we hold about you and we refuse to do so, we will, to the extent reasonable, provide you a written response as to our reasons.
8. Direct marketing
8.1 From time to time, we may use your personal information for direct marketing purposes (for an indefinite period). This includes sending you updates about new products and services we are offering. When we contact you, it may be by mail, telephone, email or SMS. Where we use or disclose your personal information for the purpose of direct marketing, we will:
- allow you to ‘opt out’ or in other words, allow you to request not to receive direct marketing communications; and
- comply with a request by you to ‘opt out’ of receiving further communications within a reasonable time frame.
You may ask to be removed from our marketing lists for any or all types of direct marketing at any time by contacting us using the details set out below.
9.1 On our website, “cookies” are generally used to record how people use our site. A cookie is small bits of information that are stored on your computer’s hard drive which records how you have used a website. It helps us improve and upgrade our website based on usage of the site. It also means that when you go back to our website, the site can give you customised options based on the information the cookie has stored about your last visit. You can generally modify the settings of your browser to prevent it from accepting cookies. While cookies do not personally identify you, they do identify your browser.
10. Questions and complaints
10.1 If you have any questions in relation to how we handle personal information, or wish to lodge a complaint about our management of personal information or a request for access to or correction of your personal information, please contact us using the contact details below:
Address: Privacy Officer
Mint Loans Pty Ltd
Airds, NSW 2560
Telephone: (02) 9835 8503
10.2 Our Privacy Officer will co-ordinate the investigation of any complaint and any potential resolution of a complaint. We will aim to resolve all complaints as soon as practicable.
11. Changes to this Policy
We may change this Policy at any time. If we make changes to this Policy we will notify you by publication on our Website. The revised version of the Policy will be effective at the time we post it.
12. Date and Version of this Policy
Date: 18th December 2018