Privacy Policy


Our Privacy Policy as at December 2018

Protecting your privacy
ClickLoans is committed to providing you with the highest levels of customer service. This includes protecting your privacy. We comply with the Privacy Act 1988 (Cth) and the Notifiable Data Breach scheme established under the Act.

Set out below is information we are required to communicate to our customers, and some additional information about our company. By accessing our website and using our services, you consent to the terms of this Policy and agree to be bound by it. Your privacy matters to us, so whether you are new to ClickLoans or a long-time user, please take the time to get to know our practices.


About us
ClickLoans is the trading name of ClickLoans Pty Ltd (ACN 601 489 856), a related body corporate of the licensed credit assistance provider, Auscred Services Pty Limited (ACN 164 638 171) (Auscred Services), which holds Australian Credit Licence 442372.

ClickLoans originates loan products funded by the Pepper Group Limited (ABN 55 094 317 665) trading as Pepper Money (Australian Credit Licence 286655) and Macquarie Securitisation Limited (ABN 16 003 297 336, Australian Credit Licence 237863).

ClickLoans and Auscred Services are subsidiaries of Auscred Limited (ACN 162 394 881), along with Lendi Pty Ltd trading as Lendi. Auscred Limited also has a joint venture with Domain Holdings Australia Ltd that is powered by Lendi, called Digital Home Loans Pty Limited (ACN 619 694 156) trading as Domain Loan Finder.

In this document, ‘ClickLoans’, ‘we’, ‘us’ and ‘our’ are references to Auscred Services, Auscred Limited, and any related bodies corporate (collectively the Auscred group of companies).


How to contact us
You can contact us during Australian Eastern Standard Time (AEST) business hours on the details below:

                Tel:         1300 797 783

                Email:    heretohelp@clickloans.com.au

                Post:      PO Box 1137, Royal Exchange NSW 1125


Your personal information
Your personal information and its protection are of utmost importance to us. When we refer to personal information, we mean information or an opinion from which your identity is apparent or can reasonably be ascertained. Personal information requested from you or held by us may include your name, age or date of birth, current and previous addresses, telephone or mobile phone number, email address, bank details, professional job title or occupation, driver’s licence number and financial details. We may hold details of your products and services you have acquired from us or have enquired about (including their status) together with any additional information necessary to deliver those products and services and to respond to your enquiries.

The personal information we hold about you may also include credit information. Credit information is a sub-set of personal information and is information which is used to assess your eligibility to be provided with finance. It 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 (CRBs). Personal information derived by a CRB from credit information held by the CRB that has any bearing on an individual’s credit worthiness and is or has been or could be used to establish the individual’s eligibility for credit is known as “CRB Derived Information”.

You may also need to provide personal information about other individuals to us, for example, personal information about your joint applicants, co-applicants, or guarantors, authorised representatives, employment referees, or your accountant or solicitor’s contact details. If so, we rely on you to inform those individuals that you are providing their personal information to us, ensure they agree to their information being provided to us, and to advise them that we can be contacted for further information (see the ‘How to contact us’ section of this statement).

If you choose not to provide certain personal information to us (i) we may not be able to provide you with the services you require or the level of service on which we aim to offer; (ii) we may be unable to tailor our offering to your preferences; and/or (iii) your experience of our offering may not be as enjoyable or as useful.


Sensitive information
Sensitive information is any 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, membership of a trade union, sexual preferences or practices, criminal record or health information. We may seek, collect, use or disclose sensitive information about you but only if that sensitive information relates directly to our ability to arrange or provide credit to you or manage the credit provided to you (including, for example, assessing hardship applications and collecting overdue payments), or is required for one of the purposes noted above, under the ‘How we use your personal information’ section of this Policy.

You expressly provide your consent to us receiving this information and holding or using it for the purposes outlined in this policy.


About credit information and ‘notifiable matters’
The law requires us to advise you of ‘notifiable matters’ relating to how we may use your credit information. You may request to have these notifiable matters (and our Privacy Policy) provided to you in an alternative form, such as a hard copy, just ask us.

We exchange your credit information with CRBs. We use the credit information that we exchange with the CRBs to assess your creditworthiness, assess your application for finance and manage your finance. 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, we may disclose this information to a CRB.

You authorise us to obtain a copy of your credit report from a CRB in accordance with the rules set out in the Privacy Act 1988 (Cth) regarding access seekers. You consent to us providing information contained in that report (including any credit-related information, arrears information, credit worthiness information and personal information) to any credit provider who may be able to provide credit to you.

We may disclose your Credit Reporting Information to joint applicants or co-borrowers with your consent. Under the Privacy Act, “Credit Reporting Information” means credit information or CRB Derived Information.

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. We explain how you can do this below.

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


You may contact the CRB to advise them that you believe that you may have been a victim of fraud. For 21 days after the CRB receives your notification, the CRB must not use or disclose that credit information. You can contact any of the following CRBs for more information: Illion (www.dnb.com.au), Experian (www.experian.com.au), and Equifax (www.equifax.com.au).


How we collect personal and credit information
We may collect personal information in a number of ways, including:

  • directly from you, for example, when you provide information by phone, in application forms, or other agreements, or when you submit your personal details through our websites (e.g. during an application or via clickloans.com.au); from your joint applicants, co-applicants or guarantors;

  • from your representatives, e.g. solicitors, conveyancers, builders, agents;

  • from referral partners, who refer your business to us;

  • from third parties such as our survey or competition websites, marketing websites, related companies, CRBs or your representatives;

  • from the organisations and entities identified under the ‘When we disclose your personal information’ section below, including our related entities;

  • from publicly available sources of information;

  • from our own records; when you visit our websites; and/or

  • when legally required to do so – for example, in the provision of specific credit services.

 

If we have obtained your information through any of these methods and you would like a list of these entities or websites, please contact us at privacy@clickloans.com.au.

If you feel you have not given us consent to use your details or would like to be removed from our call or email lists, please contact us at heretohelp@clickloans.com.au.


How we use your personal information

The primary purpose for which we collect information about you is to enable us to perform our business activities and functions (primarily credit activities) and to provide the best possible quality of customer experience.

Your personal information may be used to: verify your identity; assist you to gain approval or provision of a product or service; provide the services you require; administer and manage those services such as payments; inform you of ways the services provided to you could be improved or additional services that you may benefit from; marketing services (explained below); conduct appropriate checks for credit-worthiness and for fraud; research and develop our services provided, either directly or referred; and to gain an understanding of your information and credit or financial needs so we can provide you with a better service.

Your personal information is also collected so that we, and our related entities can promote and market services to you (including by way of direct mail, telemarketing, email, SMS and MMS messages). This is to keep you informed of products, services and special offers and we may continue after you cease holding an active product or service through us. If you would like to opt out of this, please email us at heretohelp@clickloans.com.au


When we disclose your personal information
Your information may be disclosed to persons or companies within the Auscred group of companies for the purposes noted above.

We will never sell your information to any party outside of the Auscred group of companies. However, in order to deliver the services you require we may disclose your personal information to people or organisations outside of the Auscred group of companies. This may include:

  • your joint applicants, co-applicants or guarantors;

  • your representatives or advisers (e.g. your solicitors, accountants, conveyancers, builders, agents);

  • our professional advisers, including our accountants, auditors, and lawyers;

  • organisations who manage our business, marketing and corporate strategies and/or sponsors or promoters of any competition that we conduct to promote our services;

  • credit providers, funders, agents, Australian Banks, and non-bank lenders (e.g. for credit-related purposes such as credit approval, credit-worthiness, credit rating, credit provision and financing);

  • credit-reporting bodies and fraud-checking agencies;

  • our related entities (e.g. the Auscred group of companies, and their respective partnerships, joint venture entities, agents, contractors or external service providers for the operation of their business);

  • our referral partners;

  • providers of credit, financial, or insurance services;

  • mortgage insurers and title insurers;

  • other comparison sites, mortgage brokers, or providers of investment finance, or credit (where legal for us to do so);

  • the police or other relevant authorities or enforcement bodies;

  • government and regulatory authorities or organisations (such as our External Dispute Resolution Scheme or ASIC, as required or authorised by law); and/or

  • internet service providers or network administrators (for example, if we have reason to suspect you have committed a breach of our terms and conditions or have otherwise been engaged in any unlawful activity and we reasonably believe such disclosure is necessary).

We may use external organisations for customer enquiries; mailing operations; billing and debt-recovery functions; information technology services; marketing and telemarketing; market research; and website usage analysis. This means we disclose your personal information to them.

You expressly consent to us providing your information to these persons or organisations for our primary credit activity or secondary purposes.

Your personal information is disclosed to these organisations only in relation to us providing our services to you. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

Mortgage Insurers
We may disclose personal information and credit-related information to the lenders mortgage insurers and the title insurers (collectively, Mortgage Insurers).

Where permitted by the Privacy Act 1988, the Mortgage Insurers may disclose your personal information and credit-related information to us and to third parties including: the CRBs listed below; rating agencies; the Mortgage Insurer’s related entities, service providers, agents, contractors and external advisors; reinsurers, other mortgage insurers and mercantile agents; payment system operators, other financial institutions and credit providers; other parties for the purposes of securitisation and fraud prevention; your guarantor or proposed guarantor; your referees and advisers; government and other regulatory bodies; and other entities.

Where permitted by the Privacy Act 1988, the Mortgage Insurers may seek and obtain commercial and consumer credit-related information from a CRB including (but not limited to) information concerning your credit worthiness or credit history; and information about overdue payments.

Where permitted by the Privacy Act 1988, the Mortgage Insurers will hold, use and disclose your personal information and credit-related information for the purposes of securing and administering lenders' mortgage insurance for your mortgage, including: assessing whether to provide insurance, including to assess the risk of you defaulting or the risk of a guarantor being unable to meet their liability; managing and varying the insurance; dealing with claims; enforcing a mortgage and recovering the proceeds of sale; assessing hardship; conducting risk assessment and management involving securitisation; for fraud prevention; for credit scoring, portfolio analysis and reporting; to comply with regulatory requirements; to verify personal information and credit-related information provided to it; or for any purpose required or permitted under the insurance contract, the Insurance Contracts Act 1984 (Cth) and the Privacy Act.

If the personal information and credit-related information is not disclosed to the Mortgage Insurer(s), it will not be possible for the Mortgage Insurer to process the credit provider’s request for insurance and we may not be able to arrange finance for you or provide other services.


Transfer of information overseas
In order to supply you with the best service possible, we or the Auscred group of companies may transfer personal information we have collected about you to someone in a foreign country, but only if permitted to do so under the Australian Privacy Principles.

Some of the above external organisations and entities may be located outside of Australia. You should note that while they will often be subject to confidentiality or privacy obligations, they may not always follow the particular requirements of Australian privacy laws. Overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

The Auscred group of companies has service providers based in the Philippines, who assist in processing credit applications.

We do not utilise offshore personnel for the purposes of marketing or sales. We will not share any of your credit information with a credit reporting body, unless it has a business operation in Australia.


Unsolicited information
Sometimes people share information (including sensitive information) with us we have not sought out. This could be through using our website or, for example, requesting us to assess or assist in a hardship application.

If we receive unsolicited personal information (including sensitive information) about you, we will determine whether we would have been permitted to collect that information. If we determine that we would have been permitted to collect that information, we will handle the information the same way we do with other information that we seek from you. If we determine that we would not have been permitted to collect that information, and the information is not contained in a Commonwealth record, we will destroy or de-identify it as soon as practicable, but only if it is lawful and reasonable to do so. Often, it is not possible for us to neatly unbundle this information then destroy or de-identify only certain sections or parts of it and we may need to store this information for future use, for example, to help resolve disputes or to assess future applications by you.

We have many security safeguards in place to protect the information from interference, misuse, loss, unauthorised access, modification or disclosure.


Sharing with CRBs
We will disclose information about you to a CRB when you are applying for credit, you have obtained credit from us, or if you guarantee or are considering guaranteeing the obligations of another person to us. When we give your information to a CRB, it may be included in reports that the CRB gives other organisations (such as other lenders) to help them assess your credit worthiness. Some of that information may reflect adversely on your credit worthiness, for example, if you fail to make payments or if you commit a serious credit infringement (like obtaining credit by fraud). That sort of information may affect your ability to get credit from other lenders.


Direct Marketing
We take pride in the products and services that we offer. And we love keeping you informed as to the best offers in the credit and financial market place. However, first and foremost we respect your privacy and understand that not everyone wants to be contacted regarding sales and marketing.

If you do not wish to be contacted by ClickLoans, please contact us at heretohelp@clickloans.com.au and we will remove you from our call and email lists.

We may conduct marketing activities via email, telephone, SMS, IM, mail, or any other electronic means. We may also market our products to you through third-party channels (such as social networking sites). We will always let you know that you can opt-out from receiving our third-party marketing.

With your consent, we may disclose your personal information to third parties such as brokers or agents, or for the purpose of connecting you with other businesses or customers. You can ask us not to do this at any time. We will never sell your personal information to any external organisation. We will not use or disclose sensitive information about you for direct marketing purposes unless you have consented to that kind of use or disclosure.


Opt-Out
You can let us know at any time if you no longer wish to receive direct marketing offers from ClickLoans by emailing your request to heretohelp@clickloans.com.au. We will process your request as soon as we can.


Cookies and web beacons

Cookies
 A ‘cookie’ is a small text file placed on your computer by a webpage server that may later be retrieved by webpage servers. We use cookies on our website to provide you with a better website experience. When you visit the ClickLoans website or related landing pages to read, browse, submit or download information, our system will record/log your IP address, the date, and time of your visit to our site, the pages viewed, and any information downloaded. We may automatically collect non-personal information about you such as the site from which you linked to our websites. We do not personally identify you by this information. You can configure your browser to refuse cookies or delete existing cookies from your hard drive. Rejecting cookies may have the effect of limiting access to or functionality of parts of our website. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services.

Web beacons
 A web beacon is typically a transparent graphic image invisible to the user that is placed on a website. The use of a web beacon allows the website to record the simple actions of the user (such as opening the page that contains the beacon) through a tracking pixel.

We may use web beacons (and cookies) for purposes such as site usage analytics, advertising auditing and reporting, as well as content and “advertising/marketing personalisation”. We may share any data collected from web beacon (and cookies) with third parties to provide you with relevant advertising when browsing third party networks and websites (Third Party Websites) such as Google and Facebook.


Information from third parties
Our website may contain links to Third-Party Websites (e.g. third-party providers of goods and services). We make no representations or warranties in relation to the privacy practices of any Third-Party Website and we are not responsible for the privacy policies or the content of any Third-Party Website. Third-Party Websites are responsible for informing you about their own privacy practices. If you access Third-Party Websites through our website and those third parties collect information about you, we may also collect or have access to that information as part of our arrangements with those third parties. Where you access a Third-Party Website from our website, cookie and web beacon information, information about your preferences or other information you have provided about yourself may be shared between us and the third party.


Advertising and tracking
We may advertise on Third-Party Websites. When you view our advertisements on Third-Party Websites, the advertising company may use cookies, and in some cases, web beacons, to collect information such as the server your computer is logged onto, your browser type, the date and time of your visit and the performance of their marketing efforts. When you access our website after viewing one of our advertisements on a Third-Party Website, the advertising company may collect information on how you utilise our website (e.g. which pages you view) and whether you commenced or completed an online application.


Online applications
When you send a completed online application to us, we retain the information contained in that application. We are then able to use that information to provide any services that you require. You may also be able to suspend and save online applications, so you can complete and send the applications at a later time. If you suspend or save your application, the information that you have entered will be retained in our systems so that you may recover the information when you resume your application. Online applications that have been suspended or saved may be viewed by us.


E-consent
By providing your email address and clicking ‘submit’ on any online form, application, calculator, tool, or query, you consent to receiving notices and other documents from us by email to the email address provided, and understand that if you provide this consent: we may no longer send you paper copies of notices and other documents; and you should regularly check your email address for documents. You also confirm that you have the facilities to print any notice or document that we send you by email, if required.


Accurate information
We take all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that information depends to a large extent on the information you or others provided to us. If you wish to make any changes to your personal information, please contact us at heretohelp@clickloans.com.au.

We will generally rely on you to inform us if the information we hold about you is inaccurate or incomplete. You may also request access to the personal information we hold about you by contacting us. We will respond to your request within a reasonable period. We will give access in the manner you have requested if it is reasonable to do so. We may charge you a fee to access the information. The fee will not be excessive and will not apply to the making of the request. We may deny you access to your personal information in certain circumstances, for example, if required or authorised by or under an Australian law or a court/tribunal order, or if it would be likely to prejudice enforcement related activities by an enforcement body, if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If we decide not to give you access, we will provide reasons for the refusal and information on how you can complain about the refusal.


Storage and security
We store information in different ways, including in paper and electronic form.

The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are through: confidentiality requirements of our employees; document storage security policies; security measures for access to our systems; only giving access to personal information to a person who is verified to be able to receive that information; control of access to our buildings; and electronic security systems, such as firewalls and data encryption on our websites.

We take protecting the security of your personal information seriously. We have a response plan that is designed to enable us to contain, assess and respond to suspected data breaches in a timely fashion, and to help mitigate potential harm to affected individuals.

We may store your information using cloud or other types of networked / electronic storage formats. As electronic or networked storage can be accessed from anywhere via an internet connection, it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed here or those we referred to from time. We regularly review developments in security and encryption technologies. However, it is important to remember that the use of email and the internet may not always be secure, even with these safeguards in place.

When we no longer require your information, and we are legally permitted to, we take reasonable steps to destroy or de-identify the information. However, sometimes it is impossible or impractical to completely isolate the information then completely remove all traces of the information, and we may store the information for future use, such as to help resolve disputes between us or assess future applications by you. The same security safeguards will be in place to protect the information, as detailed in this Privacy Policy.


Doing business without identifying you
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 provide you with the option to remain anonymous or to use a pseudonym, for example, when you make general inquiries about our business or current promotional offers. We do not adopt government related identifiers (such as your tax file number or driver’s licence number) as a means of identifying you.


Complaints and further information
If you have a complaint about how we handle your personal information, we want to hear from you.

Internal Dispute Resolution (IDR)
 You are always welcome to contact us to let us know about your complaint or feedback at:

Privacy Officer, ClickLoans

                Tel:         1300 797 783

                Email:    privacy@clickloans.com.au 

                Post:      PO Box 1137, Royal Exchange NSW 1125

We have a formal procedure for investigating and dealing with privacy breaches or complaints. Once our Privacy Officer receives a complaint, whether it is in writing or verbally, the Privacy Officer will commence an investigation with the relevant business unit from which the alleged breach stemmed to determine the nature of the breach and how it occurred. We may contact you during the process to seek any further clarification if necessary. If a breach is found, the Privacy Officer will escalate the matter to management so that the process can be rectified to prevent any further breaches from taking place. We will also contact you to inform you of the outcome of the investigation. We will endeavour to resolve all investigations within a reasonable time.

By giving us as much information as possible, you will help us resolve things faster. If you have any supporting documentation, please have it handy when you raise your concern(s). We will try to acknowledge your complaint within 5 business days and try to respond to your complaint within 45 days. Where we are unable to do so, we will send you an email or letter advising of the reasons for any delay, and your right to complain to our EDR scheme.

External Dispute Resolution (EDR)
 If you are dissatisfied with our Internal Dispute Resolution process, you can make a formal complaint to our External Dispute Resolution provider, the Australian Financial Complaints Authority (AFCA), which can be contacted on:

                Tel:         1800 931 678

                Email:    info@afca.org.au 

                Web:     www.afca.org.au 

                Post:      Australian Financial Complaints Authority, GPO BOX 3, MELBOURNE VIC 3001

Time limits may apply to complain to AFCA and so you should act promptly or otherwise consult the AFCA website to find out if or when the time limit relevant to your circumstances expires

Alternatively, you can contact the Office of the Australian Information Commissioner (OAIC) which can be contacted at either www.oaic.gov.au  or by calling 1300 363 992.


Changes to our Privacy Policy
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations, technology, the law, and market place practices. As a consequence, we may change this Privacy Policy from time to time or as the need arises. All personal information held by us will be governed by the most recent policy, available on our website or by request.