This Privacy Policy sets out how Acquired Financial Services Pty Ltd aims to protect the privacy
of your personal information, your rights in relation to your personal information managed by us
and the way in which we collect, hold, use and disclose your personal information.
In handling your personal information, Acquired Financial Services Pty Ltd will comply with the
Australian Privacy Act 1988, , including the 13 Australian Privacy Principles, in the Privacy Act),
and/or the New Zealand Privacy Act 1993 , including the 12 New Zealand Privacy Principles
(where relevantas applicable), and all other relevant laws, regulations and codes relating to
privacy and personal information (‘Privacy Law’).
Unless stated otherwise, this Privacy Policy is relevant to the personal information of individuals
who are our current or former customers, as well as any other individuals we may deal with (for
example, our customers’ guarantors, directors and shareholders or individuals we deal with in
other capacities as part of our business).
This Privacy Policy may be updated from time to time. You should review it periodically so that
you are aware of any changes.
What kind of personal information do we collect?
Personal information is information or an opinion about an identified, or reasonably identifiable,
individual.
The kinds of personal information Acquired Financial Services Pty Ltd collects and holds varies
according to the specific product or service being provided and may include, but is not limited to,
your:
(a) contact and identification information, such as your name, address, email address, telephone
number and date of birth;
(b) information about your assets, occupation and income, account balances, account activities,
payment history and transactions with us or third parties;
(c) government identifiers and related information, such as your driver’s licence, passport and
visa particulars obtained, for example, to verify your identity or eligibility at the time you request a
product or service;
(d) other details relating to your relationship with us, including if we deal with you in a capacity
other than a customer (for example, information about agreements or other arrangements or
transactions you may have with us); and
(e) any other information lawfully obtainable under relevant Privacy Law.
How do we collect your personal information?
Where practicable we aim to collect your personal information directly from you. The
circumstances in which we may do so will vary depending on the context in which we are dealing
with you (for example, if you are a customer, according to the specific product or service we are
providing) but can include, for example, when you are:
registering or logging in to use our website;
submitting applications and other forms through our online services and/or in hard copy;
subscribing to receive alerts/e-brochures and filling in surveys or research, or
participating in promotions and competitions we offer;
contacting us for any reason including, but not limited to, reporting a problem with one of
our services or website, requesting further services or otherwise seeking our assistance;
using our services and any credit provided by us in connection with those.
There may be occasions when we collect your personal information from other sources, such as
from:
a public or commercial information services provider (such as providers of government,
business or credit information);
a third party assisting us to process an application or other transaction, confirming
information in an application or other request or assisting us to locate or communicate
with you;
vehicle dealers and other businesses involved in dealings with you and us;
your employer, such as where we are providing a novated lease.
Generally, Acquired Financial Services Pty Ltd will only collect your personal information from
sources other than you if
it is unreasonable or impracticable to collect the personal information from you; and
the collection of that personal information complies with all relevant Privacy Law.
How we use your personal information
We collect, hold, use and disclose your personal information where it is reasonably necessary for
the purposes of providing our products and services, for our other business purposes and for any
necessary related purposes. These purposes include, but are not limited to:
(a) provision of commercial and consumer vehicle leasing arrangements,
(b) processing a product application or service request;
(c) managing our products and services or other relationships and arrangements;
(d) processing receipts, invoices and payments and servicing customer accounts;
(e) responding to customer enquiries about applications, accounts, products or services;
(f) understanding customer needs and offering products and services to meet those needs;
(g) assessing, processing and investigating insurance risks or claims;
(h) accounting, billing and other internal administrative purposes;
(i) identifying and informing customers of products and services that may be of interest;
(j) notifying you about changes to our products and services;
(k) any other legal and regulatory requirements. Various laws may expressly require us to collect
your personal information, or we may need to do so in order to be able to comply with other
obligations under those laws.
(i) In Australia such laws include the Anti-Money Laundering and Counter-Terrorism Financing
Act (for example, to comply with identity verification requirements), the Personal Property
Securities Act and State and Territory real property and security interests laws (for example, to
register and search for security interests), the National Consumer Credit Protection Act (for
example, to comply with responsible lending requirements), the Financial Sector (Collection of
Data) Act, the Corporations Act and other regulatory legislation (for example, requiring us to
maintain client and transaction records, or to make reports and provide other information to
regulators such as ASIC) and the Taxation Administration Act, the Income Tax Assessment Act
and other taxation laws (for example, to comply with information requests issued by the
Commissioner of Taxation).
(ii) In New Zealand such laws include the Anti-Money Laundering and Countering Financing of
Terrorism Act 2013 (for example, to comply with identity verification requirements), the Tax
Administration Act 1993 (for example, to comply with record keeping requirements) and, to the
extent necessary, the Credit Contracts and Consumer Finance Act 2003 (for example, to comply
with the Responsible Lending Code);
(l) enforcing our rights, including undertaking debt collection activities and legal proceedings; and
(m) undertaking business funding and development activities.
Where personal information is used and disclosed, we take steps reasonable in the
circumstances to ensure the personal information is relevant to the purposes for which it is to be
used and disclosed. You are under no obligation to provide your personal information to us.
However, without certain information from you, we may not be able to provide our services to you
or any other relevant customer.
Disclosures of your personal information
We may disclose your personal information for purposes such as those listed above and we will
always do so consistently with our privacy obligations.
Third parties to whom we may disclose your personal information include:
(a) our related entities in Australia, New Zealand and overseas;
(b) administrative services providers, such as mailing houses, printers and call centre operators;
(c) legal, settlement and valuation service providers;
(d) data processing and market research service providers;
(e) regulatory bodies, law enforcement authorities and toll operators in New Zealand, Australia
and overseas;
(f) financial and other advisors;
(g) other participants in financial and payment systems, such as other banks, credit providers,
clearing entities and credit card associations;
(h) insurers, assessors and underwriters;
(i) brokers and other distributors;
(j) your guarantors and security providers;
(k) debt collectors; and
(l) credit reporting bodies and other information providers.
Credit reporting
We comply with all Privacy Law that applies to the collection, use and disclosure of credit
information, including the Australian Credit Reporting Privacy Code and the New Zealand Credit
Reporting Privacy Code 2004 (as applicable) in our handling of your credit-related personal
information.
Credit-related personal information is a type of personal information which includes information:
(a) about your credit history or creditworthiness;
(b) about your past experiences with us and other lenders;
(c) about the kinds of credit products you have had or sought;
(d) about how you have managed your obligations;
(e) contained in a credit report about you which is obtained by us from a credit reporting body
(CRB); and
(f) about your creditworthiness that has been derived by us from such a credit report about you.
Credit-related personal information that we may collect and hold includes:
your name, address and date of birth, occupation (including the name of your employer
or organisation and any previous employers) and your driver’s licence number;
your banking or credit card details and certain financial information about you including a
statement of your assets and liabilities;
the fact that you have applied for consumer credit, or you are a guarantor in respect of
that credit application and we have accessed your credit report to assess that application;
the fact that your organisation has applied for commercial credit, or you are a guarantor
in respect of that credit application, and we have accessed your credit report to assess
that credit application;
the fact that we provide goods and services on credit terms to your organisation;
certain publicly available information that relates to your activities in Australia and New
Zealand, and your creditworthiness;
information that, in our opinion, you have committed a serious credit infringement or
credit non-compliance action (that is, acted fraudulently or shown an intention not to
comply with your credit obligations);
insolvency information, including adjudications, discharges, suspensions of discharges
and annulments of bankruptcy, and entry into, and termination and discharge from, the
no asset procedure.
assessments, evaluations, scores, ratings, summaries and other information relating to
your creditworthiness which is derived by a CRB or us, wholly or partly based on the
above; and
administrative information relating to credit provided by us.
We collect your credit-related personal information through your dealings with us or from those
acting on your behalf. We may also obtain credit-related personal information from CRBs, who
may include this information in reports provided to credit providers to assist them to assess your
credit worthiness.
We collect, hold, use and disclose your credit-related personal information as reasonably
necessary for our business purposes and as permitted by law, including:
(a) to assess, complete and process your application for credit that you make or for which you
are a guarantor (where we are the credit provider) or to assist in assessing your application for
credit that you make or for which you are a guarantor (where we act as agent of the credit
provider);
(b) to derive assessments, evaluations, scores, ratings, summaries relating to your credit
worthiness that we use in our decision-making processes;
(c) for account review and management;
(d) to participate in the credit reporting system;
(e) to undertake debt recovery and enforcement activities; or
(f) to deal with serious credit infringements.
We may disclose your credit-related personal information to:
(a) Equifax (formerly Veda Advantage), a CRB;
(b) other credit providers;
(c) our affiliates and related entities in New Zealand, Australia and overseas;
(d) current or prospective guarantors or security providers;
(e) other CRBs (for example, if you fail to meet your payment obligations or commit a serious
credit infringement, we may be entitled to disclose this to a CRB);
(f) your agents, referees, employer, executors, administrators, trustees, guardians or attorneys;
(g) your and our professional advisers;
(h) other credit providers;
(i) organisations involved in securitisation arrangements or debt assignments; and
(j) administrative service providers, such as providers of credit assessment, management and
debt collection services.
We may disclose to Equifax or any other CRB, any failure by you to meet your payment
obligations in relation to consumer credit and the fact that you have committed fraud or other
serious credit infringement. Equifax may include information which we provide in reports to other
credit providers to assist them to assess your creditworthiness.
Equifax’s policy about the management of credit-related personal information for Australia can be
found at www.equifax.com.au/credit-reporting-policy or for New Zealand can be found at
www.equifax.co.nz. Equifax can be contacted using the following details:
Australia
Equifax
by post: Equifax – Customer Resolutions, PO Box 964, North Sydney NSW 2059
by phone: 1300 762 207
by email: corrections@equifax.com.au
(visit Equifax’s website at www.mycreditfile.com.au for their most up-to-date contact details)
New Zealand
By post: Public access Information Services & Solutions (NZ). Equifax (NZ Ltd, Private Bag
92156, Victoria Street, Auckland
By phone: 0800 692 733
By email: publicaccess.nz@equifax.co.nz
(visit Equifax’s website at www.mycreditfile.co.nz for their most up-to-date contact details).
In Australia you can ask a CRB not to use or disclose your credit-related personal information for
a period of 21 days without your consent if you believe on reasonable grounds that you are, or
are likely to be, a victim of fraud, including identity fraud.
In New Zealand, you can ask a CRB not to use or disclose your credit-related personal
information for a period of 10 working days without your consent if you believe on reasonable
grounds that you are, or are likely to be, a victim of fraud, including identity fraud.
CRBs may use credit-related personal information they hold to respond to requests from us or
other credit providers to “pre-screen” you for direct marketing. You can ask a CRB not to do this.
Overseas disclosures
We may disclose your personal information (including your credit-related personal information) to
overseas recipients in order to provide our services and products and for administrative, data
storage or other business management purposes. It is not practicable to list all of the countries to
which your information may be transmitted from time to time, but we transfer information between
Australia and New Zealand, and it is likely that other such countries will include the United States
of America, Japan, Singapore and Hong Kong.
Before disclosing any personal information to an overseas recipient, we take steps reasonable in
the circumstances to ensure the overseas recipient complies with relevant Privacy Laws or is
bound by a substantially similar privacy scheme to that which is in place in New Zealand and
Australia, unless you specifically consent to the overseas disclosure taking place without such
steps being taken, or the disclosure is otherwise required or permitted by law.
Direct marketing
We may use and disclose your personal information in order to inform you of products and
services that may be of interest to you.
In the event that you do not wish to receive such communications, you can opt out by following
the instructions for doing so in the communications we send to you.
Security of your personal information
We may hold your personal information (including your credit-related personal information) in
physical form or in electronic form on our systems or the systems of our service providers.
We take steps reasonable in the circumstances to ensure that the personal information we hold
is protected from misuse, interference and loss and from unauthorised access, modification or
disclosure. We hold personal information in both hard copy and electronic forms in secure
databases on secure premises, accessible only by authorised staff, and follow procedural
safeguards that meet or exceed the relevant Privacy Law.
We require third parties handling personal information on our behalf to follow equally compliant
standards of security and confidentiality.
We will destroy or de-identify personal information in circumstances where it is no longer
required, unless we are otherwise required or authorised by law to retain the information.
Access and correction to the personal information that we hold about you
We take steps reasonable in the circumstances to ensure that personal information we hold is
accurate, up-to-date, complete, relevant and not misleading.
You have a right to access and seek correction of your personal information (including your
credit-related personal information) that is collected and held by us. This is subject to some
exceptions specified in the Privacy Act 1988 (Cth) (Australia), and the Privacy Act 1993 (New
Zealand).
If at any time you would like to access or amend the personal information we hold about you, or
you would like more information on our approach to privacy, please contact our Privacy Officer in
accordance with the contact details set out below.
We will grant access to personal information to the extent required by applicable Privacy Law
and will take reasonable steps to amend personal information where necessary and appropriate.
To obtain access to your personal information:
(a) you will have to provide proof of identity. This is necessary to ensure that personal
information is provided only to the correct individuals and that the privacy of others is protected;
(b) we request that you be reasonably specific about the information you require; and
(c) we may charge you a reasonable administration fee which reflects the cost to us for providing
access in accordance with your request. We will not charge you for making the request.
If we refuse your request to access or correct your personal information, we will provide you with
written reasons for the refusal and details of the ways in which you can make a complaint. We
will also take steps reasonable in the circumstances to provide you with access to your personal
information in a manner that meets yours and our needs.
If you are dissatisfied with a refusal of a request to access or correct your credit information, you
may make a complaint to the Australian Information Commissioner / New Zealand Privacy
Commissioner or to an applicable external dispute resolution scheme if Acquired Financial
Services Pty Ltd is a member (we will provide details of any such scheme in our response to
such a request for access or correction).
In the event that we correct your personal information previously disclosed to another entity and
you request that other entity to be notified of the correction, we will take reasonable steps in the
circumstances to do so unless impracticable or unlawful.
Complaints and Disputes
If you wish to complain about the way in which we collect or handle your personal information,
including your credit-related personal information, or if you believe we have breached any
Privacy Law, you can contact our Privacy Officer using the details below.
Following a complaint, our Privacy Officer will commence an investigation into your complaint.
You will be informed of the outcome of your complaint following completion of the investigation.
At all times, privacy complaints:
(a) will be treated seriously;
(b) will be dealt with promptly;
(c) will be dealt with in a confidential manner; and
(d) will not affect your existing obligations or impact on the commercial arrangements between
you and us.
In the event you are dissatisfied with the outcome of your complaint, you may refer the complaint
to the Australian Information Commissioner / New Zealand Privacy Commissioner or an
applicable external dispute resolution scheme if relevant to the complaint and Acquired Financial
Services Pty Ltd is a member (we will provide details of any such scheme in our response to
such a request for access or correction).
How to contact us
Please direct all privacy queries and complaints to our Privacy Officer at:
Acquired Financial Services
3/114 Colemans Rd Carrum Downs Vic 3201
Email: enquiries@acquiredfinance.com
