PRIVACY POLICY

1. Introduction

This Privacy Policy Consent and Acknowledgement ( Policy) applies to personal and credit related information collected by Asset Rental Group (Holdings) Ltd ACN 637 141 998.

In this Policy:

ARG and/or we and/or our and/or us means Asset Rental Group (Holdings) Ltd ACN 637 141 998 of Unit 3, Block V, 391 Park Street Regents Park NSW 2143.

You and/or your means customers, and borrowers or guarantors who are individuals.

Services means creating and accessing lending accounts, monitoring payment plans, participating in groups and any other features or content we may add in the future.

The Policy outlines how we collect, hold, use and disclose your personal information and safeguard your privacy. The Policy also explains how we manage your credit related information, how we interact with you online, and you can make enquiries or complaints about the personal information that we hold about you.

Your privacy is important to us, and we are bound to comply with the Privacy Act 1988 (Cth) (the Privacy Act), the Australian Privacy Principles (APPs) and the Privacy (Credit Reporting) Code 2014. 

A copy of the APPs may be obtained online at the Office of Australian Information Commissioner’s website at: 

https://www.oaic.gov.au/privacy/australian-privacy-principles/read-the-australian-privacy-principles

We value the privacy of individuals, and we are committed to safeguarding the personal information we hold about you. 

We may update or change this Policy from time to time, including to take account of new or amended laws, new technology or changes to our operations. If we do so, we will publish the updated Policy on our website. All personal information held by us will be governed by our most recently updated Policy.

We confirm that if you provide any personal information about another individual then we will rely upon you to inform him or her of the details contained in this Policy.

2. The Personal Information We Collect

Personal Information in this Policy adopts the same meaning as defined in the Privacy Act and means any information or opinion about an identified individual or, or an individual who is reasonably identifiable whether that information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.

In general, ARG collects personal information that is reasonably necessary for us to provide you financial products and services and to administer these products.

The personal information you consent to us collecting and holding will depend upon the type of information, products and services that you request from us and may include but is not limited to the following:

  • Your full name and date of birth;
  • Contact details including your residential address, email and telephone/mobile numbers;
  • Government issued identification documents such as Drivers licence or Passport;
  • Financial information (of you or your business) such as income, expenses, financial assets and liabilities;
  • Bank account details; and
  • Your Citizenship status.

Generally, we do not collect sensitive information about you such as your race, political or religious beliefs, criminal records or medical history unless required or permitted by law or where you consent for us to do so. Sensitive information will only be collected if it is relevant to your product or the service or function you are engaging us to provide. If applicable, this will be communicated to you. We will not collect sensitive information about you where this is expressly prohibited by local law. 

We may also collect personal information to provide you with news, updates and invitations (if you opted in to receive this information),

You acknowledge that if you do not provide us with the personal information we ask for, we may not be able to deliver our products or Services effectively or at all.

3. How We Use And Collect Your Personal Information

We use and collect personal information about you which is reasonably necessary to provide our Services to you including but not limited to the following:

  • To establish your identity and assess your application for our Services;
  • Tell you about our products and Services that we believe may interest you, unless you ask us not to;
  • Administer our Services and carry out our internal operations to manage our relationship with you;
  • Manage our risks and help identify and investigate and report illegal activity, such as fraud;
  • Conduct and improve our businesses and improve our customers’ experience;
  • Comply with our legal obligation, such as those relating to taxation and anti money-laundering and counter-terrorism financing and assist Government and law enforcement agencies or regulators.

Without such personal information, we may not be able to process your application or provide you with an appropriate level of service.

4. How Personal Information Is Collected

ARG collects your personal information in the following ways:

  • Directly from you (including by telephone, electronically via our website, email, SMS, our platform, our service providers platform or during conversations between you and our representatives);
  • From your nominated third party, such as a Broker, financial advisor, referrer, agent or introducer;
  • From publicly or commercially available sources for the purpose of complying with customer due diligence obligations under relevant legislation (such as anti-money laundering laws).

If we need to obtain additional sensitive information about you, we will ask for your consent where required by law.

When you use our website, and any tablet or mobile applications, we may collect information about your location or activity including the date of and time of visits, which pages are viewed, how you as the user navigate through the website and interact with the webpages (including fields completed in form and applications), IP address, telephone number, information about the device used to visit our website and whether you’ve accessed third party sites. Some of this information is collected using cookies.

5. The Storage of Personal Information

The information we hold about you will be stored electronically in secure data centres located in Australia owned by either ARG or our service providers.

We use a range of physical and electronic security measures to protect the security of the personal information we hold for example:

  • Access to information systems is controlled through identity and access management;
  • Employees are bound by internal information security policies and are required to keep information secure;
  • All employees are required to complete training about information security.

No information transmitted over the internet can be guaranteed to be secure and we cannot guarantee any information you provide us with, or we receive from you is secure. However, where transmission of information occurs by way of the internet, we take steps to protect the security and integrity of personal information. We also keep records of our interactions with you (including by telephone, email and online)

6. The Disclosure of Personal Information

We may disclose your personal information to other ARG companies. We may also disclose your personal information to organisations external to ARG. These include:

  • Your advisers, accountants, auditors, agents and service providers and anyone to whom you have agreed we may provide your information to;
  • Other organisations who provide products or services to You jointly with us, or who we believe can offer services that will be of use to you;
  • Our service providers including credit reporting agencies, collection agencies, legal advisers, and external dispute resolution scheme/s and any other agents, contractors, or service providers;
  • Where we are required or permitted to do so by law.

We also require all our service providers to comply with the Privacy Act and APPs.

7. The Disclosure of Personal Information Overseas

When You apply for one of our products, your personal information for the purposes of any Anti-Money Laundering obligations may be disclosed, encrypted and temporarily stored with service providers located outside Australia.

For international transactions, we may provide your personal information to a corresponding international service provider in order to process the transaction. The countries we disclose your information to, will depend on the details of the transaction you ask us to carry out.

8. The Electronic Transactions Act 1999 (Cth)

The Electronic Transaction Act 1999 (Cth) requires that, before we can communicate with you electronically (email or SMS), you must give us permission under the Act for us to communicate with you in that way.

When you apply for one of our products, you will be providing your permission for us to:

  • Electronically format and send you any information that we are obliged to provide;
  • Enter into a funding agreement by way of digital signatures;
  • Enter into a guarantee agreement (if applicable) by way of digital signatures;
  • Enter into a Direct Debit agreement by way of digital signatures;
  • Send You electronic messages (by email or SMS), rather than providing paper copies.

In giving this permission, you agree to:

  • Using the relevant computer programs and having sufficient internet capacity to interact with our system;
  • Regularly checking your email Inbox and/or SMS inbox;
  • Not hold us responsible if any properly sent electronic message does not reach you; and
  • Notifying us of any changes to your electronic addresses and indemnifying us from any liability if You fail to do so.

9. The Credit Related Information We Collect

When you apply for credit, propose to be guarantor or use our services or products, we need to know if you are able to meet payments under your agreement with us. We also want to avoid giving you further credit if this would put you in financial difficulty.

We may collect the following Credit related information from you or about you, and hold that information for the purposes of providing our Services to you:

  • Details of your financial position including loans, mortgages, debt balances and the term of any loans you may have entered into;
  • Information as to your repayment history of loans and debts including compliance with payments;
  • Information as to your credit score and whether you have defaulted on repayments of loans or debts
  • Any payment arrangements as a result of defaults and /or serious infringements of those payment arrangements;
  • Information as to credit defaults, court proceedings, corporate and personal insolvency;
  • Information obtained from Credit Reporting Bodies (CRB) in relation to your credit;
  • Information disclosed to us by you or any related third party;
  • Information available publicly;
  • Information held by Government authorities; and
  • Information held by any related body corporate to us.

One of our checks involves obtaining a credit report about you. Credit reports contain information about your credit history which helps credit providers assess your credit applications, verify your identity and manage accounts you hold with them. Credit reporting bodies collect and exchange this information with us.

The Privacy Act 1988 (Cth) limits the information that credit providers can disclose about you to CRBs, as well as the ways in which credit providers can use credit reports.

10. The Information Exchanged With Credit Reporting Bodies

The information we may exchange with a CRB includes your identification details, what type of loans you have, how much you have borrowed, whether you have met your loan payments and if you have committed a serious credit infringement (such as payment default). We also ask the CRB to give us an overall assessment of your creditworthiness.

11. ARG Service Providers

We may use the following (without limitation):

  • Equifax Pty Ltd www.equifax.com.au
  • greenID  gbg-greenid.com
  • Ezidebit www.ezidebit.com

12. Why We Collect and Use Credit Related Information

We use credit related information to confirm your identity, assess your creditworthiness and application for our Services under our credit assessment criteria, manage our relationship with you and collect overdue payments.

CRBs with whom we exchange information may include the information in reports they provide to other credit providers to assist them to assess your creditworthiness. You can obtain a copy of the CRB’s policy about the management of credit related information by contacting them or from their website.

If you have been or have reason to believe that you are likely to become a victim of fraud (including identity fraud), you can ask the CRB not to use or disclose the credit related information it holds about you.

13. How to Access, Update, and Correct Your Personal and Credit Related Information

You can ask for access to the personal and credit related information we hold about you. You can also ask for corrections to be made.

We may charge you for any reasonable costs incurred by us to access your personal information which is not credit related. You will be charged our reasonable costs of accessing your credit-related information if you have already sought access to it in the past 12 months.

There is no fee for correcting your personal information. If we disagree that your information should be corrected, We will tell you why in writing.

We can deny or limit access to your personal information if we cannot identify you, the information relates to commercially sensitive or privileged material, or if your request is vexatious. Whatever the outcome, we will write to you explaining our decision.

14. Data Breaches

We are aware of our responsibilities to notify you in the event of a notifiable data breach pursuant to our duties under the APP. A notifiable data breach (NDB) occurs when personal information is accessed or disclosed without authorisation or is lost and is likely to result in serious harm.

If we have reasonable grounds to believe that there has been a data breach, pursuant to the NDB Scheme, we will:

  • provide notice by way of a formal statement to the Office of the Australian Information Commissioner; and

Either:

  • Notify all individuals whose personal information was part of the NDB;
  • Notify only individuals at risk of serious harm from the NDB; or
  • If neither options above are practicable, we will publish a copy of the statement to our website and take all reasonable steps to publicise the contents of the statement.

For more information on the NBD scheme, please see:

https://www.oaic.gov.au/privacy-law/privacy-act/notifiable-data-breaches-scheme

15. Contacting Us

If you are concerned about how your personal information is being handled or if you have a complaint about a breach by us of the Privacy Act, the Code or the APPs, you can contact our Privacy Officer on:

  • Telephone: 1300 200 120
  • Email: admin@arg.ltd

 

If you are not satisfied with the way we handled your complaint, you may lodge a complaint to the Office of the Australian Information Commissioner.

GPO Box 5218

Sydney NSW 2001

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

www.oaic.gov.au

This Privacy Policy was published on 28 April 2023