Fair Go Finance Pty Ltd; and Fundco Pty Ltd (trading as Capfin) (“we”/”us”/”our”) endeavour at all times to comply with the Privacy Act 1988 and the Australian Privacy Principles which together will be referred to in this policy as “Australian Privacy Law”.
You are not required to provide us with your name or any personal information if you do not wish to. You are free to use any name allowed by law. We, however, will not deal further with you without obtaining your real name and other verifiable pieces of personal information.
3. The kinds of personal information we collect
As a result of your visit to our website, we may collect and store information about your visit to this website including:
- The domain name and IP address of the computer from which you accessed the internet;
- The date and time you accessed the website;
- The internet address of the website from which you linked directly to our website;
- The pages you accessed while visiting the website; and
- Through the use of websites, software and internet tracking devices such as cookies, anonymous identifiers and session variables, we may also collect your email address.
Your internet service provider or the providers of your internet browser software may also collect such information for their own purposes. We are not responsible for the collection, storage and use of such information by these entities and refer you to their respective privacy policies.
As a result of you dealing further with us, whether as a prospective customer, an actual customer, guarantor and prospective guarantor, contractor, supplier or service provider, we may collect and store personal information from you such as:
- Your name;
- Address, previous addresses and how long you have lived at those addresses;
- Date of birth;
- Your employer, previous employers and how long you have been in such employment;
- Your email address;
- Your telephone numbers; and
- The details of any references you supply, including the names and addresses of your referees.
If you apply to us for employment, we may also collect and store personal and, in addition, sensitive information about you including your:
- Education, training and other qualifications;
- Work history;
- Professional or trade associations or union membership;
- Hobbies and other interests; and
- Criminal history.
4. How we collect your personal information
We may collect personal information about you from your visit to our website through the use of technologies such as anonymous identifiers, session variables, and cookies. You may be able to set your internet web browser to block or limit cookies. Some features of our website may not work as efficiently or not at all if you have done so.
As a result of you dealing further with us, we may collect personal information directly from you and this may be in person, over the telephone, by mail, over the internet, by email or fax or by completion of an application or consent form whether on-line or otherwise.
- Apply to us for credit;
- Agree to guarantee credit from us to another person;
- Receive credit from us;
- Apply to us to vary the terms of your payments under your (consumer) credit contract on the grounds of hardship; or
- Apply for employment with us;
We may collect personal, credit and sensitive information about you from other sources when it is impractical or unreasonable for us to collect it directly from you. Among these other sources may be:
- A credit reporting body;
- Someone authorised by you such as an agent, broker, accountant, solicitor, financial counsellor, introducers or a guarantor;
- A referee;
- An employer;
- A government body;
- Another financial institution;
- A professional or trade association or trade union
- Our agents.
And we may collect that information directly from them in person, over the telephone, by mail, over the internet, by email or fax or by completion of an application or consent form whether on-line or otherwise.
5. How we hold your personal information
We use our best endeavours and take all reasonable steps to secure your personal information including:
- Maintenance of a secure environment for storage of information whether in hard copy or in electronic form;
- Requiring that access to such information be confined to authorised personnel only;
- Using technology such as encryption and password protection to secure any information kept in electronic form.
We are not responsible for the security of any computer or other device which you use to access our website.
6. The purposes for which we collect, hold, use and disclose your personal information
If you are a user of our website, a prospective customer, a customer or guarantor of a customer’s credit, a contractor or supplier of goods and services to us, a job applicant or other person from whom we collect, hold, use and disclose your personal information we shall do so only for those purposes which are:
- Permitted by Australian Privacy Law;
- Necessary for:
- The administration of any contract of supply of goods or services to or by us;
- The provision of our products to our customers;
- The consideration, assessment and administration of any proposed guarantee of credit;
- Assessment and processing of any job application;
- Otherwise for the administration and management of our business;
- For the improvement of website useability;
- Required by law; such as under the Anti-Money or Laundering and Counter Terrorism Financing Act 2006 (Cth);
- Required in order to investigate or assist with any investigation into any complaint about the conduct of our business, in particular, under Australian Privacy Law;
- To otherwise enforce any term of any contract or other right which arises out of our dealings with you; to communicate with you, by way of direct marketing, information about our products and services. If you do not wish us to do so, you can “opt out” of such communication by informing us in person, by telephone, by facsimile, by post or by email;
- To search and/or register any Personal Property Securities;
- Necessary as part of providing your Personal Information and Data to third parties and other potential credit providers, funders or other intermediaries should you not meet our lending criteria;
- To anybody who represents you, such as finance brokers, lawyers, and accountants;
- Necessary as part of a prospective sale, transfer or restructure of our business;
- To anyone, where you have provided us consent; or
- To otherwise communicate with you or the purposes outlined above.
In addition, if you apply to us for credit or receive credit from us, we will collect, hold, use and disclose your personal information in order to:
- Assess your credit application including that of any proposed guarantor;
- Manage your credit contract;
- Manage or administer your finance with organisations such as third party suppliers, printing and postal services, call centres, lenders mortgage insurers, trade insurers and credit reporting bodies;
- Consider any application for variation of your payments whether or not on the grounds of hardship; and
- Collect any debt or otherwise enforce any rights arising under your consumer credit contract.
You hereby expressly agree and consent to us using, providing, selling and exchanging your personal, credit and sensitive information and all customer data (Personal Information and Data) with third parties, including other credit providers and alternate service providers such as credit file repair services, budgeting services and rental services.
The Personal Information and Data we may provide and/or sell to third parties and other credit providers and alternate service providers, includes any and all information provided to us or obtained by us as a result of you accessing our website and/or applying to us for credit including (without limitation) your identification details, the type of loans you have, how much you have borrowed and/or asked to borrow, whether or not you have met your loan payment obligations and if you have committed a serious credit infringement (for example, fraud).
We may also share some of your personal information but not your credit or sensitive information:
- To associated businesses that may want to market products to you;
- To companies that provide referrals, information and infrastructure systems to us;
- To anyone, where you have provided us consent;
- To investors, agents or advisers, or any entity that has an interest in your finance or our business;
- To organisations that provide products or services used or marketed by us;
- To investors, agents or advisers, or any entity that has an interest in your finance or our business;
- To your employer, referees or identity verification services.
You further agree and consent to us using and/or selling your Personal Information and Data to third parties and other credit providers and alternative service providers who may in turn use your Personal Information and Data for any of the purposes for which we collect and hold it, including to assess any credit application you may submit to those persons.
Where permitted by law or for any of the purposes mention above, we can exchange, provide and/or sell your Personal Information and Data to third parties including:
- Service providers, for example credit providers and lenders;
- Alternative service providers including those offering credit repair services, consumer leases and budgeting services;
- Market providers for the sale or distribution of my Personal Information and Data;
- Those to whom we or other credit providers or alternative service providers or any of the third parties outsources certain functions, for example direct marketing, statement production, debt recovery and information technology support;
- Government and law enforcement agencies or regulators;
- Credit reporting bodies and credit providers.
7. Direct Marketing
To keep you up-to-date with our brand and help you see and find products we believe are relevant to you, we will use some of the information collected from you to engage in online advertising.
We target adverts to you when you are on other websites and apps using a variety of digital marketing networks and ad exchanges such as AdWords, Bing and Facebook. These adverts use a number of different technologies such as pixels, ad tags, cookies and mobile identifiers as well as specific services offered by some sites and social networks such as Facebook’s Custom Audience service.
The adverts you see will be based on information we hold about you and/or your previous use of the Fair Go Finance website, such as your search history and the product types you have engaged with on our website.
We will not provide any information that may identify you as an individual, such as your name, address or telephone number to any of these digital marketing networks and ad exchanges.
You expressly agree and consent to us providing your Personal Information and Data to other credit providers and third parties if your application for credit from us is unsuccessful for any reason. You understand and acknowledge that we may receive payment from these parties for providing your Personal Information and Data. Once your Personal Information and Data has been provided, other credit providers may offer credit to you subject to their own legal and other obligations. These credit parties are not associated with us in any way and you may need to lodge a fresh credit application with them and meet their lending criteria. We are in no way endorsing these other credit provider’s services nor suggesting that they will offer to lend you money nor encouraging you to do business with them.
We may disclose your personal information, including credit and sensitive information, to other parties as part of a process of merger, acquisition, sale of our business or our other assets and, before doing so, will give you notice and an opportunity to opt out of the provision of such information in that instance.
If, for any of the above purposes, we disclose your personal information to any supplier of services to our business or to any prospective purchaser of our business which we shall do so only if it is necessary for the purposes listed above, we shall:
- Do so in accordance with Australian Privacy Law;
- Obtain assurances from those suppliers that they comply with Australian Privacy Law.
8. Whether we supply your personal information to overseas recipients
We supply your personal information to overseas recipients as part of our information technology systems. Those recipients are likely to be in the following countries: South Africa and the United States of America.
9. How you may access your personal information held by us
You may request access to your personal, sensitive and credit information held by us by identifying yourself in person, by post, by facsimile or by scanned attachments to an email and sending your request for access to us at Complaints Officer, Fair Go Finance, PO Box 884, WA 6210 or Fax No. 1800 324 746 or email@example.com
If we are unable to grant your access to personal, sensitive or credit information, we will give you our reasons in writing within a reasonable time. These may include where providing the information to you may:
- Reveal personal information about another individual person;
- Pose a threat to the health or safety of another individual person;
- Not be permitted by law;
- Reveal internal information of a commercially sensitive nature which is not required to be disclosed to you by Australian Privacy Law.
10. How you may correct any personal information we hold about you which is incorrect
If you believe any personal information which we hold about you is incorrect, please contact us in person by telephone, by facsimile, by email, identify yourself and tell us what information which we hold about you is, in your belief, incorrect and how you want it changed.
If we cannot agree to the change to the information which you have requested, we will give you reasons in writing.
11. How you may complain about how we deal with your personal information
If you are not satisfied with the reasons referred to above or otherwise have any complaint about how we collect, hold, use or disclose your personal information please contact our Complaints Officer who will then follow our Internal Dispute Resolution process.
Our Complaints Officer can be contacted by email: firstname.lastname@example.org, by telephone on 1300 324 746 or writing to: Fair Go Finance, PO Box 884, WA 6210, or by speaking to any representative of our business who will refer you to the Complaints Officer.
If you are not satisfied with our Internal Dispute Resolution process, you may refer your complaint to our External Dispute Resolution Scheme.
Our External Resolution Scheme is:
Australian Financial Complaints Authority (AFCA)
GPO Box 3
Melbourne VIC 3001
Tel: 1800 931 678
Fax: 03 9613 6399
You can, of course, at any time, refer directly to:
The Office of the Australian Information Commissioner
GPO Box 2999 CANBERRA ACT 2601
Tel: 1300 363 992
12. Changes to this policy
Changes to the law;
Changes to technology;
Changes to our systems.