Privacy policy

Last updated July 2018

Credit Simple recognises the importance of protecting Personal Information about individuals. This Privacy Policy explains how Credit Simple collects, uses and discloses your Personal Information. It also explains how your Personal Information may be used by our Related Bodies Corporate. This Privacy Policy does not limit our rights and obligations under Privacy Laws.

  1. Introduction
    • 1.1 This Privacy Policy sets out how your Personal Information may be collected, used, stored and disclosed by Credit Simple, including where you appoint Credit Simple as your agent to request information about you from a Credit Reporting Body. By accessing the Credit Simple Website and/or using our Services you agree to be bound by this Privacy Policy.
    • 1.2 Capitalised terms used in this Privacy Policy have the meaning given to them in clause 15.
  2. Changing this Privacy Policy
    • 2.1 This Privacy Policy may be amended from time to time, by publishing an updated Privacy Policy on the Credit Simple Website. Any subsequent access to or use by you of the Credit Simple Website will constitute an acceptance of the amended Privacy Policy. You should check from time to time to see if any part of this Privacy Policy has been updated.
    • 2.2 This Privacy Policy does not limit our rights or obligations under the relevant Privacy Laws.
  3. Personal Information we collect
    • 3.1 We may collect the following Personal Information from or about you, where the information is reasonably necessary for our business purposes, including to provide our Services to you:
      • name, gender and date of birth
      • driver’s licence or passport details, and in Australia only, Medicare card details
      • phone number, email address, residential address and previous address
      • any other information that you provide to us or authorise us to collect in connection with a specific Service offered on the Credit Simple Website.
  4. How we collect your Personal Information
    • 4.1 Personal Information about you may be collected by us in a number of circumstances, including if you: (a) register with us by creating an account; (b) use our Services; (c) lodge an enquiry with us by email or telephone; (d) complete any surveys that we issue; or (e) contact us for any reason, including with support queries.
    • 4.2 We collect Personal Information from you directly, unless it is unreasonable or impracticable to do so or if we collect it from the following:
      • Third parties that support our Services – we may collect Personal Information from the following third parties: (a) a Credit Reporting Body (on your behalf); (b) suppliers who supply services to us; (c) our referrers and advertisers; and (d) publicly maintained records;
      • Bank(s) – Money Simple enables you to access information relating to all of your chosen Banks in one place. If you use Money Simple, in order to make this Service efficient, Credit Simple and/or Proviso may extract: (a) all information available from your Bank(s) using your Bank Credentials (even if you only request to see part of that information at any particular time, for example, by selecting specific chosen accounts); and (b) that information on each day that you log into your Credit Simple account; and
      • Related Bodies Corporate – we may access Personal Information from our Related Bodies Corporate in order to receive specialised services in connection with the Services that we provide to you (for example, we may collect information from Proviso if you use Money Simple).
    • 4.3 We also collect, use, store and disclose non-identifiable information relating to your use of the Credit Simple Website and our Services.
  5. Purpose of collection of Personal Information
    • 5.1 Primary purpose: We collect Personal Information for the primary purpose of being able to operate our business, including to provide our Services to you. If you do not provide all of the Personal Information we request (or authorise us to collect that information), you may not be able to use our Services. Collection of Personal Information for the primary purpose of the Services includes:
      • to assess, process and manage your application to use our services – including for identity verification purposes (this includes utilising identity verification service providers such as Green ID and providing identity verification information to a Credit Reporting Body to confirm your identity and current contact details);
      • to enable you to get your credit score and other Credit Information from a Credit Reporting Body (as well as updates when certain Credit Information changes occur), and to enable you to request a Credit Reporting Body to correct and update the Credit Information it holds about you;
      • to assist you to obtain information from credit providers where requested by you;
      • to enable you to see your chosen Bank accounts in one place, if you use Money Simple; and
      • to display Discounts available to you through Clear Name Services – see clause 8 below.
    • 5.2 Additional purposes: In addition, we collect Personal Information so that we can carry out the following actions:
      • to provide you with a more targeted experience when you use our Services;
      • to validate, update and/or enhance our products, services and databases (including those of our Related Bodies Corporate);
      • to undertake research, analytics and/or benchmarking;
      • to identify and understand user needs;
      • to connect future publicly available data sets into our services;
      • for our business development and marketing purposes – for example, see clause 11 below;
      • to send you, and display on the Credit Simple Website, details about products and services and special offers that might interest you, from us and from third parties – see clause 11 below;
      • for any other purpose you have consented to or which is permitted under the Privacy Laws; and
      • for internal record keeping, audit and compliance purposes and to comply with our legal and regulatory obligations.
  6. Disclosure of Personal Information
    • 6.1 You authorise us to disclose Personal Information to any of our Related Bodies Corporates for the purposes set out in clause 5. In addition, we may disclose Personal Information to:
      • Credit Reporting Body – if you request your credit score or other Credit Information using the Credit Simple Website – refer to clause 6.2 below;
      • Proviso – if you use Money Simple Services – refer to clause 6.3 below;
      • Clear Name– if you use Credit Simple to access your credit report – refer to clause 8 below;
      • Our service providers – such as Green ID and other identity verification service providers, Inspectlet (refer to clause 6.5 below), IT contractors, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who need to have access to your Personal Information to provide their services to us;
      • Organisations that provide products or services used or marketed by us – including intermediaries, trustee companies, financial institutions and securitisers;
      • Other – (i) our employees or contractors to the extent reasonably necessary to fulfil our obligations to you; (ii) anyone considering acquiring an interest in our business or assets; (iii) other entities or persons to the extent reasonably necessary for the purposes set out in clause 6.2 or clause 6.3 above; (iv) any law enforcement, legal, government or regulatory agency, where such disclosure is required or authorised by law; and (v) other individuals or companies authorised by you.
    • 6.2 Credit Reporting Body – By requesting access to your Credit Information using the Website, you also acknowledge and agree that we may disclose your identity verification information and contact details to a Credit Reporting Body. The relevant Credit Reporting Body may use that information to update or correct information held by it (including to create a record and credit score if you don’t already have one where the Territory is New Zealand) and to provide its credit reporting services. The collection, use, storage and disclosure of Personal Information by a Credit Reporting Body, and your rights to request access to and correction of that information, is subject to the Credit Reporting Body’s privacy policy. For more information about how a Credit Reporting Body may collect, use, store and disclose your Personal Information, please refer to the Privacy Policy at www.illion.com.au (where the Territory is Australia), and www.illion.co.nz (where the Territory is New Zealand).
    • 6.3 Proviso – the provision of Money Simple Services, on the Credit Simple Website, is made possible through the specialised services provided to us by Proviso (one of our Related Bodies Corporate). If you use Money Simple, you authorise us to disclose your Money Simple Information to, and to collect your Money Simple Information from, Proviso and you authorise Proviso to use your Money Simple Information in accordance with Provio’s Privacy Policy available at www.proviso.com.au/privacy (where the Territory is Australia), and www.proviso.co.nz/privacy/ (where the Territory is New Zealand).
    • 6.4 Third Party Analytics – We have engaged Inspectlet to analyse the activities of visitors to this Website, and Inspectlet’s authorized use of cookies and other tracking technologies enable it to have access to Personal Information of visitors to this Website. Such access to and use of Personal Information by Inspectlet is governed by Inspectlet’s Privacy Policy.
    • 6.5 Advertisers and credit providers – You may choose to provide Personal Information directly to any advertiser (such as a credit provider), including as a result of using a link from the Credit Simple Website to an advertiser’s website. If you do so, the collection, use, storage and disclosure of that information by the relevant advertiser will be subject to the advertiser’s privacy policy. Any disclosures you make are subject to the advertiser’s privacy policy and terms and conditions.
    • 6.6 Linked Sites – Our Website may link directly to websites operated by third parties (Linked Sites). You acknowledge that Linked Sites are not operated by us. We are not responsible for the content or practice of the Linked Sites or their privacy policies regarding the collection, storage, use and sharing of your Personal Information. We encourage you to always read the applicable privacy policy and terms and conditions of any Linked Site.
    • 6.7 You acknowledge that we do not control and are not responsible for any use of Personal Information by any third party that you disclosure, or authorise us to disclose, your Personal Information to.
  7. Direct Marketing
    • 7.1 From time to time we may use your Personal Information which we hold to provide you with:
      • updates about your Credit Information (Credit Information Alerts) and, if applicable, your use of Money Simple (Money Simple Updates); and
      • current information about our services, informative articles, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any third party (Marketing Communications).
    • 7.2 By providing us with your Personal Information, you consent to us (including our Related Bodies Corporate) using your information to contact you on an ongoing basis for these purposes, including by mail, email, SMS, social media, telephone and other electronic means.
    • 7.3 If you do not wish to receive Marketing Communications, you may at any time unsubscribe from receiving Marketing Communications by responding via the channel in which you received the Marketing Communication or by updating your “communication preferences” on the “Account” page of your Credit Simple account. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
    • 7.4 Credit Information Alerts will include factual information and updates about your Credit Information and Credit Simple account. Credit Simple may send you Credit Information Alerts until your Credit Simple account is terminated or suspended. You acknowledge and agree that even if you opt out of receiving Marketing Communications, we will still send you essential information such as Credit Information Alerts.
    • 7.5 If you use Money Simple, we will send you Money Simple Updates to provide you with factual information and updates about your use of Money Simple and connected financial institutions. Credit Simple may send you Money Simple Updates until you terminate or suspend your use of Money Simple by removing all of your chosen accounts (refer to clause 9.1 of the Terms of Use). You acknowledge and agree that even if you opt out of receiving Marketing Communications, we will still send you essential information such as Money Simple Updates.
  8. Clear Name Services
    • 8.1 Clear Name provides an online debt repayment service, which is available exclusively to Credit Simple members, by clicking through to the Clear Name Website (Clear Name Services). When you use Credit Simple to access your credit report, you authorise Credit Simple to disclose information from your credit report to Clear Name, on your behalf. This enables Clear Name to calculate any repayment which is offered by participating lenders that may be available to you (your Discounts). If applicable, Credit Simple will display your Discounts, with your credit report, on the Credit Simple Website.
    • 8.2 You can then elect to repay applicable debts, and utilise your Discounts, by linking from the Credit Simple Website to the Clear Name Website. If you repay a debt via Clear Name, Clear Name may notify Credit Simple, to enable Credit Simple to assist with ensuring that the Credit Reporting Body updates your credit report as soon as possible.
    • 8.3 The Personal Information that we disclose to Clear Name on your behalf will be collected, held, used and disclosed by Clear Name in accordance with Clear Name’s Privacy Policy available at www.clearname.com.au/content/privacy-policy (where the Territory is Australia), and www.clearname.co.nz/content/privacy-policy (where the Territory is New Zealand).
  9. Sending information overseas
    • 9.1 We operate in both Australia and New Zealand so your Personal Information may be accessible in both countries to ensure we are able to provide our services to you.
    • 9.2 We will not send your Personal Information to countries other than Australia and New Zealand without obtaining your consent or otherwise complying with the Privacy Laws.
    • 9.3 However please be aware that where your Personal Information is disclosed to a third party service provider, credit provider or other entity (in accordance with an express term of this Privacy Policy), we do not control whether those entities operate overseas or may allow Personal Information to be accessible overseas. We encourage you to always read the applicable privacy policy and terms and conditions of those entities.
  10. Provision of information about others
    • 10.1 Please be aware that the Terms of Use prohibit the use of our Services on behalf of any other person. We will not ask you to provide us with information about someone else. However, if you provide unsolicited Personal Information to us about someone else, you must ensure that you are authorised by the relevant individual to disclose their Personal Information to us for the purpose for which it is provided.
  11. Use of Cookies
    • 11.1 We may use technology known as a “cookie” to collect statistical information about you when using internet browsing, mobile or tablet applications. Cookies are small pieces of information captured when your device is used to access online content. They can record information about your visit to the Credit Simple Website, allowing it to remember you the next time you visit and provide a more meaningful experience.
    • 11.2 You can switch off cookies by adjusting the settings on your web browser. If you disable the use of cookies on your web browser or remove or reject specific cookies from the Credit Simple Website or the Linked Sites then you may not be able to gain access to all of the content and facilities on those sites.
    • 11.3 We allow advertisers on Credit Simple and their service providers to also use cookies on our site to track performance.
  12. Storage & Security
    • 12.1 We will use all reasonable endeavours to keep your Personal Information in a secure environment, however this security cannot be guaranteed. Our procedures are designed to prevent your Personal Information being accessed by unauthorised personnel, lost or misused. If you reasonably believe that there has been unauthorised use or disclosure of your Personal Information, please contact us using the contact details below.
    • 12.2 Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving Personal Information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Law requirements.
  13. Your access to your Personal Information
    • 13.1 It is important to our relationship that the Personal Information we hold about you is accurate and up to date.
    • 13.2 You may request access to any of the Personal Information we hold about you at any time. To request access to the Personal Information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
    • 13.3 If you consider that any information we hold about you is incorrect, you should contact us to request that it is updated. Please let us know if there are any changes to the Personal Information you have provided to us. While we take reasonable steps to ensure that the Personal Information held by us is up to date, we will generally rely on you to assist us in informing us if the information we hold about you is inaccurate or incomplete.
    • 13.4 We will respond to your request within a reasonable period of time and, where reasonable and practicable, grant access to the information in the manner requested. An explanation will be provided to you if we deny you access to your Personal Information we hold.
  14. Further Information and complaints
    • 14.1 You may request further information about the way we manage your Personal Information or lodge a complaint by contacting us using the contact details below.
    • 14.2 We will deal with any complaint by investigating the complaint, and providing a response to the complainant within 30 days in Australia, or within 20 days if you are in New Zealand, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree an alternative time frame with you.
    • 14.3 Personal information that we collect is either held by us (at our offices in New Zealand or Australia) or on our behalf. Some information we hold may be stored in “the cloud” in databases on our behalf by service providers based overseas.
  15. Definitions and interpretation
  16. How to contact us