Privacy Policy

1.

Terms Used in this Privacy Policy

a.

Credit Reporting Code of Conduct means the Privacy (Credit Reporting) Code 2014 (CR Code) and the Privacy Regulation 2013 reflected in Part IIIA of the Privacy Act 1988 (Cth); and

b.

Australian Privacy Principles (APPs) means the 13 Australian privacy principles from Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012, which amends the Privacy Act 1988 (Cth), a copy of which is provided in annexure A to this policy.

2.

Use and Disclosure of Personal information

a.

We are bound by the Credit Reporting Code of Conduct and must adhere to the Australian Privacy Principles.

b.

When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The personal information we hold about you may also include credit information.

c.

Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies. The kinds of personal information we may collect about you include your name, date of birth, address, account details, occupation, and any other information we made need to identify you.

d.

If you are applying for finance we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings and expenses.

3.

Collection of Your Personal Information

a.

We collect personal information for the purposes of assessing your application for finance and managing that finance. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. From time to time we may offer you other products and services.

b.

To enable us to maintain a successful business relationship with you, we may disclose your personal information to other organisations that provide products or services used or marketed by us. We may also disclose your personal information to any other organisation that may have or is considering having an interest in your finance, or in our business. Where reasonable and practical we will collect your personal information directly from you. We may also collect your personal information from finance brokers and other people such as accountants and lawyers.

4.

Use and Disclosure of Your Personal Information

a.

We may disclose your personal information in the following ways:

i.

to other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services, call centres, debt recovery agents and solicitors;

ii.

to other credit providers and alternate service providers (such as credit file repair services, budgeting services and rental services);

iii.

to other credit providers and alternate service providers who may use my personal information for any of the purposes for which we can use it. I can request that this authority be withdrawn at any time;

iv.

to companies that provide information and infrastructure systems to us;

v.

to anybody who represents you, such as finance brokers, lawyers and accountants;

vi.

to anyone, where you have provided us consent;

vii.

where we are required to do so by law, such as under the Anti-Money or Laundering and Courter Terrorism Financing Act 2006 (Cth);

viii.

to investors, agents or advisers, or any entity that has an interest in our business; or,

ix.

to your employer, referees or identity verification services.

b.

Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:

i.

the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or

ii.

you have consented to us making the disclosure.

c.

We may also store information on you on our servers, and it is possible these servers are not located in Australia.

5.

Credit Information

a.

We may collect the following kinds of credit information and exchange this information with credit reporting bodies and other entities;

i.

credit liability information, being information about your existing finance which includes the name of the credit provider, whether the credit provider holds an Australian Credit Licence, the type of finance, the day the finance is entered into, the terms and conditions of the finance, the maximum amount of finance available, and the day on which the finance was terminated;

ii.

repayment history information, which is information about whether you meet your repayments on time;

iii.

information about the type of finance that you are applying for;

iv.

new arrangement information, which includes information about a variation to existing liabilities;

v.

default and payment information, which includes payments that are more than 60 days overdue and whether they have been made;

vi.

personal insolvency information, which is information that is entered into the National Personal Insolvency Index which relate to such things as debt agreements, bankruptcy personal insolvency agreements; and

vii.

court proceedings information.

b.

We exchange this credit information for the purposes of assessing your application for finance, managing that finance, discharging our functions under the Bankruptcy Act 1966 (Cth) or administering your debt agreement.

c.

This credit information may be held by us in electronic form on our secure servers and may also be held in paper form. We may use cloud storage to store the credit information we hold about you.

d.

When we obtain credit information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.

6.

Notifiable Matters

a.

The law requires us to advise you of ‘notifiable matters’ in relation to how we may use your credit information. You may request to have these notifiable matters (and this privacy policy) provided to you in an alternative form.

b.

We exchange your credit information with credit reporting bodies. We use the credit information that we exchange with the credit reporting body to assess your creditworthiness, assess your application for finance, manage your finance, and administer your debt or personal insolvency agreement.

c.

If you fail to meet your payment obligations in relation to any finance that we have provided or arranged or you have committed a serious credit infringement then we may disclose this information to a credit reporting body.

d.

You have the right to request access to the credit information that we hold about you and make a request for us to correct that credit information if needed. Please see the heading “Access and correction to your personal and credit information”, below.

e.

Sometimes your credit information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers. You can contact the credit reporting body at any time to request that your credit information is not used in this way.

f.

You may contact the credit reporting body to advise them that you believe that you may have been a victim of fraud. For a period of 21 days after the credit reporting body receives your notification the credit reporting body must not use or disclose that credit information.

7.

Direct Marketing

a.

From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.

b.

I understand that I may be offered a financial product from another lender based on their credit assessment of my application it may not be the exact same type or amount I applied for.

c.

If you do not wish to receive marketing or other information from us or third party providers, you may at any time decline to receive such information by emailing us info@spondooli.com.au

d.

If the direct marketing is by email you may also use the unsubscribe function. If the direct marketing is by text you may also use the unsubscribe function.

e.

By using the unsubscribe function in a direct marketing communication you will only unsubscribe from direct marketing from that entity / brand who sent you the communication and method of delivery. Please let us know if you would like to unsubscribe from all direct marketing from PAID International and related entities. 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.

8.

Updating your Personal Information

a.

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

b.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.

9.

Access and Correction to your Personal and Credit Information

a.

We will provide you with access to the personal and credit information we hold about you. You may request access to any of the personal information we hold about you at any time.

b.

We may charge a fee for retrieving and supplying the information to you.

c.

Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.

d.

There may be situations where we are not required to provide you with access to your personal or credit information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious. An explanation will be provided to you if we deny you access to the personal information we hold about you.

e.

If any of the personal or credit information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information at the time of the request. Otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.

f.

We may need to consult with other entities as part of our investigation.

g.

If we refuse to correct personal information we will provide you with our reasons for not correcting the information.

10.

Using Government Identifiers

a.

If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.

11.

Business Without Identifying You

a.

In most circumstances it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates or current promotional offers.

b.

We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.

12.

Security of your Personal Information

a.

We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

13.

Complaints

a.

If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact our complaints officer by writing to The Privacy Officer – Capital Supply Australasia, Level 9, 461 Bourke Street Melbourne VIC 3000 or by email info@spondooli.com.au

b.

We will acknowledge your complaint within seven days of the date we receive it. We will provide you with a decision on your complaint within 30 days.

c.

If you are dissatisfied with the response of our complaints officer you may make a complaint to the Privacy Commissioner which can be contacted via the Office of the Australian Information Commissioner website (www.oaic.gov.au) or on 1300 363 992.

14.

Further Information

a.

You may request further information about the way we manage your personal information by contacting us.

15.

Change in our Privacy Policy

a.

We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.

b.

As a consequence we may change this privacy policy from time to time or as the need arises. You may request this privacy policy in an alternative form.

c.

This Privacy Policy came into existence on Wednesday, 13 October 2021.