Privacy policy

Last updated January 2017

Credit Simple (Australia) Pty Ltd ACN 614 444 790 (Credit Simple, also referred to in this policy as “us” “we” and “our”) provides users of Credit Simple’s services (referred to in this policy as “you” and “your”) with the services set out in our Terms of Use

This Privacy Policy has been developed in accordance with the Privacy Act 1988 (Cth) (Privacy Act). It 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, DBCC Pty Ltd, part of the Dun & Bradstreet (Australia) Pty Limited ACN 006 399 677 group (D&B). The D&B group means DBCC Pty Ltd; Decision Intellect Pty Ltd; Perceptive Communications Pty Ltd; Dun & Bradstreet (Australia) Pty Limited; and Credit Simple (Australia) Pty Ltd ACN 614 444 790.

Credit Simple recognises the importance of protecting the privacy of our customers and other third parties who provide personal information to us, whether directly or indirectly. Credit Simple is not a credit reporting body, and will never share information about your creditworthiness to other agencies.

By accessing www.creditsimple.com.au (Website) you agree to be bound by this Privacy Policy, and the Terms of Use (in each case, as updated from time to time).

This Privacy Policy may be amended from time to time, by publishing an updated Privacy Policy on our Website. However, we will not amend your rights to stop receiving direct marketing, as set out in section 7 below. Any subsequent access to or use by you of the Website will constitute an acceptance of the amended Privacy Policy.

  1. Personal information we collect
    The personal information we collect from or about you is the information that is reasonably necessary for our business purposes, including to provide services to you. We may collect a range of personal information from or about you, including your:

    • name;
    • date of birth;
    • driver’s licence number;
    • marital status;
    • phone number;
    • email address;
    • residential or business address;
    • nationality;
    • employment history;
    • income;
    • assets; and
    • liabilities.

    We will only collect sensitive information revealing your race, ethnicity, trade union memberships or other sensitive information if you have given us express consent to do so and:

    • the information is reasonably necessary for us to carry out our functions or activities;
    • the use of the information is required or authorised under an Australian law, court or tribunal order; or
    • the information is necessary for the establishment, exercise or defence of a legal claim.

    By disclosing your personal information to us you consent to the collection and use of your sensitive information in accordance with this Privacy Policy.

    Access to credit information held by D&B
    You may use the Website to request access to and correction of credit information about you held by D&B (Credit Information). Credit Information may include information about credit that was applied for or provided to you for domestic, household or personal purposes as well as information about you as a guarantor of a loan. As detailed in section 3 of the Terms of Use, we will only request Credit Information about you from D&B, or correction of that information, as your agent, when you authorise us to do so. We will only use your Credit Information for the purposes set out in section 4 below.

    This Privacy Policy also applies to any other personal information that you provide to us or authorise us to collect.

    From time to time we may collect, use, store and disclose non–identifiable information relating to your use of the Website. For example, we may record information such as the areas of our website that you visit along with the time, date and URL of the pages you access, your IP address and / or the previous website that you visited before linking to the Website.

  2. How we collect your personal information
    Normally we collect information from you directly, unless it is unreasonable or impracticable to do so. We may also collect information about you from third parties such as from D&B, our contractors who supply services to us, through our referrers (such as financial advisers), from a publicly maintained record or from other individuals or companies as authorised by you.

    Personal information about you may be collected by us in a number of circumstances, including if you:

    • register with us by creating an account;
    • ask us to obtain your credit score or any other Credit Information from D&B, for example, if you submit a request for this information on the Credit Simple Website – as noted above, we will only request Credit Information about you from D&B as your agent, when you authorise us to do so, as detailed in section 3 of the Terms of Use;
    • lodge an enquiry with us by email or telephone;
    • request that we obtain an indicative quote and/or approval for a loan from a lender on your behalf;
    • apply to work with us; or
    • complete any surveys that we issue.
  3. If we are unable to collect your personal information
    The personal information that we collect is necessary to enable us to provide the services to you. If you do not provide all of the personal information we request, you will not be able to use our services.
  4. Purpose of collection of your personal information
    We collect your personal information for the primary purpose of being able to operate our business, including to provide services to you. In addition we collect your personal information so that we can carry out the following actions (each a Purpose):

    • to assess, process and manage your application to use our services;
    • to provide you with products and services that you have requested from us;
    • to manage our relationship with you;
    • to enable you to get your credit score and other Credit Information from D&B and to enable you to request D&B to correct and update your Credit Information held by D&B;
    • for identity verification purposes, including utilising identity verification service providers such as Green ID and providing identity verification information to D&B to confirm your identity and current contact details;
    • to assist you to obtain an indicative quote and/or approval for a loan provided by a lender;
    • to undertake research, analytics and/or benchmarking;
    • to connect future publicly available data sets into your Website experience;
    • to contact you if we need to advise you of something;
    • for audit and compliance purposes and to comply with our legal and regulatory obligations;
    • to process and manage your application to work with us;
    • to use personal information that you have provided to us to send you details about products and services and special offers that might interest you, from us and from third parties (including credit providers) – see section 7 below; and
    • for any other purpose you have consented to or which is permitted under the Privacy Act.

    We may also use, store and disclose information that we collect in connection with Credit Simple’s services, in a fully anonymised form, for research and analytical purposes.

    If someone other than you provides us with personal information about you that we did not ask for and we determine that we could have collected this information had we asked for it, we will notify you as soon as practicable, unless to do so would constitute a breach of confidence. If we determined that we could not have collected the information, we will destroy or lawfully de–identify it.

  5. Disclosure of your personal information
    We will not disclose information that personally identifies you to any third party other than as set out in this Privacy Policy. You consent to your personal information being disclosed in connection with any Purpose to any of the following:

    • D&B – we only disclose your personal information to D&B if you request your credit score or other Credit Information using the Credit Simple Website. The personal information that we disclose to D&B is limited to your identity verification information, contact details and any other information that you expressly authorise us to disclose to D&B as part of the request application process, or when you update your details with us;
    • credit providers – we only disclose your personal information to credit providers if you have asked us to obtain an indicative quote and/or approval for a loan on your behalf – the information that we provide to credit providers will be limited to your identity verification information and email address, together with any other information that you expressly authorise us to disclose. The collection, use, storage and disclosure of that information by the relevant credit provider will be subject to the credit providers privacy policy. We do not control and are not responsible for any credit provider’s privacy policy but note that credit providers will undertake their own assessment of your creditworthiness which is likely to involve the disclosure of your personal information to D&B;
    • our service providers, such as Green ID and other identity verification service providers, IT contractors, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants and auditors, who will need to have access to your personal information to provide those services;
    • organisations that provide products or services used or marketed by us, including intermediaries (such as financial advisers), trustee companies, financial institutions and securitisers;
    • people considering acquiring an interest in our business or assets;
    • our employees, contractors or service providers, to the extent reasonably necessary to fulfil our obligations to you;
    • our related bodies corporate, to the extent reasonably necessary for the purposes set out above;
    • any law enforcement, legal, government or regulatory agency, where such disclosure is required or authorised by law;
    • other individuals or companies authorised by you; and
    • for any other purpose permitted by law.

    Some of the entities we disclose to may be located overseas, or may disclose your personal information to parties in foreign countries who are not subject to the Privacy Act. By providing your personal information to us you consent to this disclosure.

    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 of practice of the Linked Sites or their privacy policies regarding the collection, storage, use and dissemination of your personal information. We encourage you to always read the applicable privacy policy of any Linked Site.

    Disclosure of your personal information to D&B
    By requesting access to your Credit Information using the Website, you also acknowledge and agree that D&B may use the information that you authorise us to disclose to it (as detailed in this section 5) to update or correct information held on its credit bureau (including to create a record and credit score if you don’t already have one) and to provide its credit reporting services. The collection, use, storage and disclosure of personal information by D&B, and your rights to request access to and correction of that information, is subject to D&B’s privacy policy. For more information about how D&B may collect, use, store and disclose your personal information, please refer to the D&B Privacy Policy at www.dnb.com.au.

  6. Provision of information about others
    If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use, store and disclose such information for the purposes described in this Privacy Policy. For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this Privacy Policy, and consents to the disclosure and use of their information.

    Please be aware that you must not register a Credit Simple account or access Credit Simple’s services on behalf of any other person (see section 4 of the Terms of Use).

  7. Direct Marketing
    From time to time we may use your personal information that you have provided to us to provide you with current information about our services, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or any third party. By providing us with your personal information, you consent to us using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone.

    If you do not wish to receive marketing information from Credit Simple you may at any time unsubscribe from receiving such information 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.

    You acknowledge and agree that even if you opt out of receiving marketing material, we will still send you essential information that we are required to send you relating to the services we provide.

  8. Use of Cookies
    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 Website, allowing it to remember you the next time you visit and provide a more meaningful experience.

    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 our website or linked sites then you may not be able to gain access to all of the content and facilities on those websites.

  9. How you may access your information
    It is important to our relationship that the personal information we hold about you is accurate and up to date.

    You may request access to any of the personal information we hold about you, including any credit–related 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.

    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.

    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.

  10. Storage and Security
    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 disclosed of your personal information, please contact us using the contact details below.

    If we no longer need your personal information, we will take reasonable steps to destroy, delete or lawfully de–identify it, unless required otherwise by law.

  11. Further Information and Complaints
    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.

    We will endeavour to deal with any complaint by investigating the complaint, and providing a response within 15 business days, 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 alternative time frames with you.

    If you are dissatisfied with our response or wish to make a further complaint, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au/.

  12. How to contact us
    Please contact us on support-au@creditsimple.com.au if you have any questions about this Privacy Policy, the Website, our Terms of Use or any of our services.