1.             Personal Information and its importance

1.1          Personal information is information about You from which Your identity is apparent.  Protecting Your privacy is fundamental to the way We do business.  This document (the “Privacy Policy”) sets out the way We will collect, store, use and share Your personal information. It will also provide You with information about what You can do to access the personal information We have about You, the way You can have it corrected, if necessary, and what steps You can take to complain about any action taken by Us in relation to the information.

1.2          Unless defined in this Privacy Policy or the context otherwise requires, capitalised terms have the meaning given to them in the Website Terms and Conditions which can be accessed at

1.3          We may change this Privacy Policy at any time by updating it on the Website. Unless stated otherwise, any change takes effect immediately. You are responsible for ensuring You are familiar with the latest Privacy Policy. By continuing to access and use the Website, You agree to be bound by the changed Privacy Policy.

1.4          This Privacy Policy was last updated on 24 November 2017.

2.             Why we collect personal information

2.1          We collect personal information so that We and/or Our commercial partners (as applicable) can:

2.1.1                 accept and process Your application for a loan in accordance with the requirements by law;

2.1.2                 assess Your personal and/or commercial creditworthiness;

2.1.3                 make a determination about the risk of You defaulting on Your obligations to Us or Our commercial partners;

2.1.4                 undertake, where appropriate, risk assessment and management involving securitisation, credit scoring, portfolio analysis, reporting and fraud prevention and claim recovery;

2.1.5                 if Your application is successful, provide You with a loan and determine on what terms We will do so;

2.1.6                 manage Your account and communicate with You;

2.1.7                 assist in the resolution of any dispute You have with Us or Our commercial partners;

2.1.8                 provide You with information about other products or services We currently offer, or may offer in the future or are offered by Our commercial partners;

2.1.9                 in certain circumstances as disclosed in paragraph 5.1.12, sell Your personal information, or to provide that information to others who might offer services to You; and

2.1.10              satisfy any obligation We may have under law to collect personal information or make assessments.

2.2          We will not use personal information We have collected for a purpose other than that disclosed in this Privacy Policy without Your consent, or in circumstances where You would reasonably expect the use for that purpose.

2.3          If You do not provide Us with Your personal information or give Us consent to collect it from others, We will be unable to, amongst other things, process Your application and make any assessment that We are required to by law. We will therefore not be able to satisfy our internal and external obligations and may not be able to further Your application for a loan.

3.             Where we get personal information

3.1          We may obtain personal information from any of the following sources:

3.1.1                 You in the process of Your application through the Website or in other communication with You;

3.1.2                 publicly available information such as telephone directories, information on websites or from public databases such as the electoral roll;

3.1.3                 other credit providers from whom We request information;

3.1.4                 credit reporting bodies;

3.1.5                 persons or entities You have authorised to provide Us with information;

3.1.6                 Your use of the Website with the aid of “cookies”; and

3.1.7                 marketing companies from which We may acquire information in order that We may offer services to You.

3.2          Where We obtain personal information which We are either required to collect, or authorised to collect by law, We will advise you of that fact (to the extent not already reasonably advised or disclosed in this Privacy Policy).

4.             Sensitive information

4.1          “Sensitive information” is information about Your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or trade union, sexual preferences or practices, criminal record, health, genetic, or other like information.

4.2          We will not collect, use or disclose any sensitive information about You unless we have Your specific consent, and it is necessary to undertake one of the functions referred to in this Privacy Policy.

5.             Exchange of personal information

5.1          We and Our commercial partners may disclose Your personal information to:

5.1.1                 such credit reporting bodies, ratings agencies and any business which provide information about the credit worthiness of persons with whom We or one of Our commercial partners have a commercial arrangement (more detail about this appears below);

5.1.2                 other credit providers;

5.1.3                 personal and/or business referees nominated by You, including Your employer (in relation to your employment status and income);

5.1.4                 Our professional advisers, contractors and other service providers (eg. IT consultants);

5.1.5                 Your legal and financial advisers;

5.1.6                 government departments, agencies or bodies, to whom We may be required by law to disclose information supplied by You to Us;

5.1.7                 our financiers;

5.1.8                 Our contractors, agents and service providers (including debt collectors) in order that We may deal with You more efficiently or collect monies owing to Us;

5.1.9                 payment system operators (if any);

5.1.10              Our insurers, insurance underwriters/providers in relation to Our insurance policies;

5.1.11              entities who may purchase (or who may be interested in purchasing) any relevant information you may provide US or any interest in the obligations You may owe Us or any of Our commercial partners and entities (either credit licensees (credit providers or credit assistance providers) or lead providers) to whom we may sell Your personal information for a fee. The credit licensees or lead providers may either provide a service to You themselves or on-sell Your personal information to others on the same basis as Your personal information is sold to them;

5.1.12              search agents and search system providers in relation to Your residential information and other information in order to contact You; and

5.1.13              real estate agents and others to enable Us or Our commercial partners to be advised of Your current residential and other information held by them.

6.             Overseas disclosure

6.1          Any information You submit to the Website may be transferred overseas to Us or one of Our group members or commercial partners. Some of Your information might also be stored overseas as part of Our backup system, (for example if We use “cloud storage”).

7.             Credit reporting

7.1          We may also provide the following information to credit reporting agencies both in New Zealand and overseas:

7.1.1                 whether a member of Our group or one of Our commercial partners provide You with a loan;

7.1.2                 the type of loan provided;

7.1.3                 the amount of the loan provided;

7.1.4                 the date the loan was supplied;

7.1.5                 the date the loan terminated;

7.1.6                 the terms of the loan;

7.1.7                 whether payments are made on the loan;

7.1.8                 if You default in making a payment on the loan (where the amount is $150 or more and has been outstanding for 60 days or more);

7.1.9                 whether You were late in making payments and whether You make those payments up; and

7.1.10              if You commit a serious credit infringement (fraudulent activity or deliberately evading Your obligations under the loan terms).

8.             Clickstream data and cookies

8.1          Clickstreams are the paths a user takes when navigating the internet. When you visit the Website our internet service provider makes a record of your visit and logs certain information (e.g. your IP address). You consent to the collection of such information.

8.2          Cookies may be used by Us to collect information including IP addresses about people from our website. Cookies allow Us determine who has seen particular pages on the Website and how frequently. This can help Us to identify Your preferences and allow Us to recommend content We believe You’d be most interested in or would be most relevant to You.

8.3          For each visitor to the Website, we expressly collect the following non-personally identifiable information, including but not limited to browser type, version and language, operating system, pages viewed while browsing the Site, page access times and referring website address.

8.4          You may disable cookies by changing the settings on Your browser, although this may mean You cannot use all of the features of the Website.

9.             Access to and correction of your personal information

9.1          The Privacy Act 1993 provides certain statutory rights in relation to Your personal information.

9.2          Subject to limited exclusions, You can request access to and correction of Your personal information that we hold by contacting Us by way of the following methods:

9.2.1                 by email to;

9.2.2                 at our website using the contact us facilities;

9.2.3                 by mail to c/- PO Box 507 Toorak, Victoria, Australia 3142 (physical address: Suite 14, 50-58 Ross Street, Toorak, Victoria, Australia, 3142); and/or

9.2.4                 by telephone on 09 889 5892

9.3          We will endeavour to provide You with the copies of the personal information You require or to correct Your personal information within a reasonable time following receipt by Us of Your request.

9.4          If a fee will apply to supply of the information, or We are permitted by law to withhold certain information, or We are unable to correct Your personal information, We will advise You as soon as reasonably possible following receipt of Your request for that information or correction.

10.          Destruction of Information

10.1       We will destroy personal information upon Your request or as required by law. You can contact us on 09 889 5892 or by accessing our website using the Contact Us facilities. The exception to this is if the personal information is required in order to fulfill the reasonable purposes of our business or the information is required to be maintained and/or stored in accordance with the law.

11.          Complaint procedure

11.1       If you have concerns about how we manage Your personal information You may contact our internal dispute resolution team using any of the below methods:

11.1.1              by email to;

11.1.2              at our website using the Contact Us facilities;

11.1.3              by mail to c/- PO Box 507 Toorak, Victoria, Australia 3142 (physical address: Suite 14, 50-58 Ross Street, Toorak, Victoria, Australia, 3142) and/or

11.1.4              by telephone on 09 889 5892.

11.2       In the event You are not satisfied with the resolution provided You may escalate your complaint to the Privacy Commissioner using the Privacy Commissioner website or telephone 09 302 8680.

11.3       For further information about privacy obligations please visit the Privacy Commissioner website