Privacy and Credit Reporting Policy
1. Introduction At Cash Store, (ACN 668 042 804 / Australian Credit representative no. 549800), we value the importance of safeguarding individual privacy and rights concerning personal information. This document represents our comprehensive Privacy and Credit Reporting Policy (Policy), outlining how we uphold our obligations under the Privacy Act 1988 (Privacy Act) concerning the handling of personal information. This includes compliance with the Australian Privacy Principles (APPs) and credit reporting obligations as stipulated in the Privacy Act and the Credit Reporting Code, as registered under section 26S(1) of the Privacy Act.
2. What Types of Information Are Covered by This Policy?
Cash Store collects your personal information to provide the products and/or services you request from us. Some of the personal information we request is essential to adhere to credit laws and regulations. Failure to provide your personal information may hinder our ability to process your quote or application for the requested products or services.
This Policy outlines the management of “personal information.” Specific sections of this Policy are dedicated to “credit-related information,” detailed in Section 7. In the context of this Policy, “personal information” holds the meaning defined in the Privacy Act. In essence, it includes any information that can be used to personally identify you, such as your name, address, telephone number, email address, and profession or occupation.
The term “credit-related information” within this Policy comprises credit information, credit eligibility information, and credit reporting body (CRB) derived information, as defined by the Privacy Act. Credit-related information typically encompasses your name and address, contact details, date of birth, gender, credit history, details of any credit provided by credit providers, credit ratings, credit assessment scores, and information about any credit-related legal proceedings or insolvency applications relevant to you.
We may contact you to progress your quote, gather additional information, and process your application for requested products or services. Please note that all calls with us are subject to recording by Cash Store for service improvement, training, and monitoring purposes. Any personal information, including sensitive information, provided over the phone or through other means will be handled in accordance with our Privacy Policy.
- Name
- Mailing or street address
- Email address
- Telephone number
- Facsimile number
- Age or birth date
- MediCare number, driver’s license number, tax file number, and passport number
- Profession, occupation, or job title, along with relevant employment details
- Information about your income sources and expenditure details
- Details of the products and services you’ve acquired or inquired about
- Additional information provided through our website, applications, or other online means, including data collected via cookies and online technologies (discussed in section 9 of this Policy)
- Third-party account details (e.g., social network sign-ins)
- Public social profile information (e.g., name, profile picture) and the email address used for social media logins
- Any other information provided in person, during visits by our representative
- Personal information relevant to employment applications, such as qualifications and work history
- Personal information provided during participation in surveys conducted by us or third-party service providers, including survey responses.
- Accessing and using our website and online applications
- Receiving information via email or electronically provided documentation
- In-person interactions, mail, or fax
- Telephone conversations with our representatives
- Completing finance applications, whether through our website or over the phone. All calls with us may be recorded by Cash Store for the purpose of improving our service and for training and monitoring. Any personal information, including sensitive information, provided over the phone or through other means will be handled in accordance with our Privacy Policy.
- We may be unable to provide you with our products or services, either at the same level of quality or not at all.
- We may not be able to furnish you with information about products or services that you may desire, including details regarding special promotions.
- We may be unable to tailor the content of our website to your preferences, potentially leading to a less enjoyable or less useful experience on our website.
- Sending communications to you, including updates related to your finance or insurance application status, and providing access to our website and secure web services for facilitating these communications.
- Identity verification, which may involve cross-referencing the information with the document issuer or official record holder.
- Providing quotes or estimates for finance or insurance products we offer or can arrange on your behalf.
- Assessing the most suitable financier among those we represent to meet your financial goals and needs, and subsequently preparing, submitting, and advising on the outcomes of finance or insurance applications on your behalf with the financiers and insurers we collaborate with or represent.
- Managing the provision of finance, insurance, and other products throughout the duration of your contract, including periodic updates to keep your contact details current.
- Addressing inquiries and offering information or general advice about our existing and new products and services.
- Conducting business processing functions, which may involve sharing existing or updated personal information with our related corporate entities, contractors, service providers, or other third parties.
- Handling and responding to complaints made by you.
- Ensuring compliance with applicable laws, rules, regulations, lawful and binding determinations, decisions, or directions from regulatory authorities, or collaborating with government authorities as required.
7. Credit Reporting Policy
7.1. Introduction This section, Section 7, outlines our credit reporting policy. It is applicable when we provide consumer credit and/or commercial credit to individuals, acting either directly or as an agent for our financiers. Credit checks may be conducted on you and any joint account holders. For corporate customers, this may include directors, partners, or other authorized representatives as well.
It is important to note that the Privacy Act and this policy do not cover commercial credit provided to companies or other entities. However, this policy becomes relevant when an individual applies for commercial credit or when we or our financiers request a director or another authorized individual to guarantee the commercial credit offered by us to a company or another entity. This policy solely pertains to the utilization of individuals’ credit-related information in assessing their creditworthiness or suitability as a guarantor.
7.2. Collection of Credit-Related Information In addition to collecting personal information, we may gather specific types of credit-related information.
This may include but is not limited to:
- Your name and address, including previous address
- Contact details, such as telephone and email addresses
- Date of birth and gender
- Credit history, credit rating, or credit assessment scores provided by a credit reporting body, encompassing both positive and negative account conduct, such as missed or late repayments
- Details of credit extended to you by other credit providers, like financial institutions, utilities, or telecommunications providers
- Information pertaining to credit-related court proceedings or insolvency applications that concern you
- Any other personal or credit-related information reasonably required for determining whether we or our financiers will extend credit to you or your related company or entity
This information may be obtained directly from you or from third parties, including credit reporting bodies and other credit providers, to aid in the evaluation of credit extensions by us or our financiers to you or your related company or entity.
7.3. Use and Disclosure of Your Credit-Related Information The credit-related information collected and maintained by us may be utilized to support us and our financiers in determining whether to grant credit to you or your related company or entity.
The credit reporting bodies we engage with, which may include Equifax Pty Ltd and Dun & Bradstreet Inc. (Trading as illion Data Registries), are responsible for the credit information.
For inquiries and contact:
- Equifax: Telephone at (13 83 32) or online at https://www.equifax.com.au/contact. Equifax’s credit reporting policy is available at https://www.equifax.com.au/credit-reporting-policy.
- Illion: Telephone at (13 23 33) or online at https://www.illion.com.au/contact-us/. Illion’s credit reporting policy is available at https://www.illion.com.au/illion-credit-reporting-policy-australia/.
You have the right to access the credit reporting policies of any credit reporting bodies that receive your credit-related information from Cash Store. Contact the entities mentioned above to obtain a copy in an alternative format.
If you reasonably believe that you have been or are likely to be a victim of fraud, including identity-related fraud, you can request that a credit reporting body not use or disclose your credit reporting information. Such a request can be made to any of the credit reporting bodies listed above.
The purposes for which we use your credit-related information, in accordance with Part IIIA of the Privacy Act and the Credit Reporting Code, may include:
- Assessing any credit application you submit to us or our financiers, whether on your behalf or on behalf of your related company or entity
- Collecting outstanding payments owed to us or our financiers for previously extended credit
- Disclosing your credit-related information to related companies assessing whether to extend credit to you or your related company or entity
- Evaluating your eligibility as a guarantor for credit you or our financiers have offered to your related company or entity
- Disclosing your credit-related information to a third party acting as a guarantor for credit provided to you
- Sharing your credit-related information with credit reporting bodies, including but not limited to Equifax Pty Ltd and Dun & Bradstreet Inc. These bodies collect various types of credit-related information about individuals to provide credit-related services to their customers, including us.
- If you fail to meet your payment obligations or commit a serious credit infringement, we may be entitled to disclose this to credit reporting bodies, including but not limited to Equifax Pty Ltd and Dun & Bradstreet Inc.
- Disclosing your credit-related information to our financiers in connection with your credit applications
- Sharing your credit-related information with third parties providing services on our behalf, including debt collectors, credit management agencies, and other entities processing credit applications for us or providing identity verification services.
- Disclosing your credit-related information to other credit providers that are considering providing credit to you or your related company or entity.
- Using and disclosing your credit-related information for assessing and responding to access or correction requests you make.
- Responding to consultation requests from credit reporting bodies or other credit providers concerning your access or correction requests.
- Handling complaints to the Office of the Australian Information Commissioner or recognized external dispute resolution schemes related to the treatment of your credit-related information. This also includes seeking legal or professional advice in response to your complaints.
- Using and disclosing your credit-related information as required by law or court or tribunal orders.
- Any other uses or disclosures to which you have explicitly consented.
7.4. Additional Considerations Regarding Your Credit-Related Information
Where mandated by law, we will maintain a written record (which may be stored electronically) of any use or disclosure related to your credit-related information. In cases where:
- You (or your related company or another entity) submit a credit application to us; or
- You offer to guarantee the credit that we propose to extend to your related company or other entity,
and we subsequently reject your application or offer based on information provided by a credit reporting body, we will promptly inform you of this decision. Additionally, we will provide you with the name and contact information of the credit reporting body involved and any other information that the law requires us to provide.
7.5. Access and Correction
You have the right to request access to or correction of any credit-related information we have in our possession about you. Please refer to Section 12 of this policy for guidance on how to request access to any credit-related information we hold about you.
8.Direct Marketing
8.1. Objectives of Our Direct Marketing
We may use or disclose your personal information for the purpose of direct marketing, including but not limited to:
- Sharing your information within Cash Store, which includes our related corporate entities and franchisees, as well as other select companies. This enables our other divisions and businesses to contact you or offer complementary products and services. Such contact may occur as described in Section 9 of this Policy, including the delivery of more relevant advertising content.
- Serving our administrative, marketing (including direct marketing), planning, product or service development, quality control, and research purposes, conducted by us, our related corporate entities, contractors, or service providers.
- Enhancing the performance and effectiveness of marketing and advertising campaigns we conduct, including those on behalf of our financiers or other business partners, and evaluating our website’s performance.
Our direct marketing practices adhere to relevant marketing laws, such as the Spam Act 2003 (Cth), and APP 7, which pertains to direct marketing.
Typically, we may send you direct marketing communications and information about our products and services (or those of our financiers) that we believe may be of interest to you. These communications may be delivered through various channels, including mail, SMS, fax, and email, as well as in the form of targeted content and offerings, as outlined in Section 9.
You expressly acknowledge and consent to our sharing or disclosing your personal information with other third-party entities so they may directly engage in marketing with you, as described in Section 9.
8.2. Opting Out of Direct Marketing Communications
If you express a preference for a particular communication method, we will make reasonable efforts to use that method, whenever practical. If we commence sending you direct marketing communications, you may modify your preferences or opt out of receiving marketing communications from us through the following means:
- Utilizing the unsubscribe process provided within email communications or sending an email to geelong@cashstore.com.au.
- Adjusting your communication preferences via the preference center accessible through email communications.
- Contacting our customer service at 0433 946 979.
9.Our Website and Online Applications
9.1. Application of This Policy to Our Website and Online Applications
This policy extends to our websites located at cashstores.com.au. It encompasses any personal and credit-related information you furnish to us through our websites.
9.2. How Cash Store and Linked Sites Capture and Utilize Your Activity
When you visit one of our websites or use our applications, respond to a survey, participate in a promotion or competition, Cash Store and other third-party entities may typically record anonymous information. This data includes but is not limited to your IP address, the time and date of your visit, the referring URL, device details and location, carrier, site interactions (such as your use of website features), pages viewed, content accessed, search activities, lead submissions, files accessed and downloaded, browser type, operating system, and other clickstream information.
This information collected by us may be correlated with other data we hold about a user to create a comprehensive profile of their browsing, purchasing, and other activities. Such data may be used by us and shared with third parties to categorize a user and deliver personalized offers, marketing, and advertising. Activity data may be shared with advertisers for these purposes, especially when the user is an existing customer of the advertiser.
Cash Store may employ third-party advertising applications and companies to collect data and/or serve ads when you visit our websites or applications. These companies may use information (excluding your name, address, email address, or telephone number) regarding your visits to websites and other media to provide advertisements about products and services of interest to you.
9.3. Cookies and Other Online Behavioral Technologies and Methods
We employ “cookies” and other online behavioral technologies and methods to gather and store the information as described above. A cookie is a small file that remains on your computer or other device until, depending on whether it is a sessional or persistent cookie, you either shut down your computer or it reaches its expiration date (which may range from as little as 30 days to 2 years or longer in some cases).
Cookies may be utilized by us or by service providers engaged by us to offer you the full spectrum of services we provide. These cookies serve various purposes, such as remembering your preferences, recalling the websites you visit, gauging and analyzing the usage of our websites, and enhancing security. As this information does not qualify as personal information, it is not subject to the Privacy Act, and we may utilize this information for any lawful purpose. We utilize both session ID cookies and persistent cookies, including first-party cookies (e.g., Analytics Services, as explained below) and third-party cookies (e.g., Adobe Analytics). Persistent cookies may be employed to identify the sites you visit on third-party websites and tailor the advertising you encounter during future visits to those or other sites or platforms. Cookie data and other data may be sold, licensed, or otherwise provided to third parties through advertising exchanges or other data-sharing platforms for this purpose.
If you prefer not to receive any cookies, you may adjust your browser settings (such as Firefox, Google Chrome, Internet Explorer, or Safari) to either prompt or decline cookies. If you disable cookies, we may not be able to provide you with our complete range of products and services, and not all functions on our websites and applications will be accessible to you. One of the websites that enables you to control the information collected about you is Your Online Choices (www.youronlinechoices.com.au).
9.4. Security
Our websites and applications are connected to the internet, which inherently poses security challenges. Therefore, we cannot guarantee the security of information transmitted to us online. We use Secure Socket Layer (SSL) technology, where applicable, to encrypt information transmission to us. However, we cannot ensure that the information you provide won’t be intercepted while being transmitted over the internet. Consequently, any personal information or other data you send to us online is transmitted at your own risk.
9.5. Links
Our website may incorporate links to other websites operated by third parties (Linked Sites). Operators of Linked Sites may collect personal information through the use of cookies and other means. We do not make any representations or warranties concerning the privacy practices of Linked Sites, and we are not responsible for the privacy policies or content of any Linked Sites. Third-party websites are accountable for informing you about their own privacy practices.
10.To Whom Do We Disclose Your Information?
We may disclose your personal information and credit-related information to:
- Our financiers, including any financiers for whom we act as an agent.
- In cases where your relationship with us entails the sale or purchase of a vehicle, your information may be disclosed to insurers, vehicle dealerships, and private vehicle sellers related to that business, including in connection with the issuance of invoices.
- Our employees, related corporate entities, contractors, or service providers for website operation or our business processes. This may encompass fulfilling your requests and delivering services to you, such as web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, identity verification service providers, and professional advisors such as accountants, solicitors, business advisors, and consultants.
- Entities and other third-party providers, as outlined in Section 9, to offer you a more personalized experience when you visit our websites or applications, including providing you with more relevant advertising content.
- Credit reporting bodies, as discussed in Section 7.3 or as otherwise authorized under the Privacy Act and the Credit Reporting Code, registered under section 26S(1) of the Privacy Act.
- For better personalization of the products and services we offer to you, or any entities.
- Suppliers and other third parties with whom we maintain commercial relationships, for business, process outsourcing, identity verification, marketing, and related purposes.
- Any organization for an authorized purpose, with your express consent, or to comply with any law, rule, regulation, lawful and binding determination, decision, or direction of a regulator, or in cooperation with any governmental authority.
Once we disclose your personal information to a third party, your information will be managed in accordance with the relevant third party’s privacy policy.
We may combine or share any information collected from you with information obtained from any of our related corporate entities or any other third party, as described in this Privacy Policy, in a collection statement, or as otherwise permitted under the Privacy Act.
11.Do We Disclose Your Information to Parties Outside Australia?
We may, from time to time, disclose your personal information to an entity located in another country where permitted under the Privacy Act. For instance, we may disclose personal information and credit-related information to our financiers, related corporate entities, and third-party suppliers and service providers located outside of Australia. This includes our data hosting providers and other IT service providers.
Unless we reasonably believe that the overseas recipient is subject to a law or binding scheme substantially similar to the APPs, we will take reasonable steps, where practical, to ensure that the overseas recipient does not breach the relevant APPs concerning your personal information. However, this may not always be feasible, and therefore, you expressly consent to the collection, processing, use, disclosure, transfer, and storage of your personal information outside of Australia when we cannot guarantee the recipient’s compliance with the APPs. If an overseas recipient mishandles your personal information, the entity will not be held accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act. If you do not wish to provide this consent, please contact our Compliance Officer using the contact details provided in Section 14.
12.Accessing and Correcting Your Personal Information
If you wish to access or correct any of the personal information or credit-related information we have on record about you, please contact us using the details provided below. We will make every effort to provide you with appropriate means of accessing this information, such as mailing or emailing it to you. A reasonable fee may be charged to cover our administrative and other reasonable costs associated with providing this information. We will not charge a fee for simply making the request or for making any necessary corrections to your personal information.
There may be situations where we are unable to grant access to certain personal information or credit-related data. For example, we may have to deny access if doing so would compromise the privacy of other individuals or lead to a breach of confidentiality. In such cases, we will furnish you with written explanations for our refusal.
Should you believe that any of the personal information or credit-related data we hold about you is inaccurate, incomplete, or incorrect, you have the right to request corrections. We will assess the necessity for amending the information and make the appropriate changes if warranted. In instances where we do not concur that amendments are necessary, we will append a note to the personal information indicating your disagreement with it.
For any credit-related information in our possession concerning you, we will:
- Address your request for the correction of your credit-related information within 30 days (or within an agreed-upon extended timeframe, if applicable). If resolving your correction request necessitates consultation with other credit providers or credit reporting bodies, we may undertake such consultations. These bodies are authorized by law to assist us in resolving your correction request.
- If we concur with your request, promptly rectify any credit-related information about you that we determine to be inaccurate, outdated, incomplete, irrelevant, or misleading. In this case, we will inform you of the corrections made, and we will also notify any other credit provider and credit reporting body to which we had previously disclosed this information. In situations where we shared your credit-related information after you submitted a complaint but before the complaint was resolved, we will notify the recipient that you lodged a complaint and subsequently inform them of the resolution to your correction request.
- If we have independent grounds to suspect that the credit-related information we possess regarding you has become inaccurate, outdated, incomplete, irrelevant, or misleading, we will rectify this information without requiring your consultation. In such cases, we will take reasonable steps to notify you of these corrections, as well as any other entities to which we had previously disclosed the credit-related information (unless such notification is impractical).
13.How to Address Privacy Complaints
If you believe there has been a breach of your privacy, please reach out to us using the contact information provided below and provide a written account of the incident for our investigation.
If your complaint pertains to our failure to grant access to or correct any credit-related information in our possession, you have the option to lodge a complaint directly with the Office of the Australian Information Commissioner (for additional guidance, please visit oaic.gov.au) or with the Credit and Investments Ombudsman Limited, our independent external dispute resolution provider, who can also handle complaints related to credit-related information.
In situations where your complaint pertains to the handling of your credit-related information, not covered in the above scenarios, or if it concerns your Personal Information, you must initiate the complaint process with us initially. Please use the contact details outlined in Section 14 (Contacting us) below and furnish us with the necessary details for our investigation.
Our comprehensive internal dispute resolution policy (Dispute Policy) will govern the investigation and resolution of privacy breaches. To obtain a copy of this policy, please contact us using the details below. When you file a privacy complaint in line with Section 13, we will acknowledge receipt of your complaint and strive to investigate and respond in adherence to our Dispute Policy within 30 days. If the matter is complex and our investigation may require additional time, we will notify you accordingly.
We uphold the confidentiality of your complaint. Following receipt of your complaint, our representative will contact you within a reasonable timeframe to discuss your concerns and present potential resolution options. We aim to ensure that your complaint is addressed promptly and appropriately.
Should you remain dissatisfied with our handling of your complaint or our proposed resolution, you have the right to submit a further complaint to the Office of the Australian Information Commissioner (for further information, please visit oaic.gov.au). This office can provide detailed guidance on the subsequent steps in the complaints process. If your complaint relates to credit-related information we maintain about you, you may opt to lodge a supplementary complaint with the Australian Financial Complaints Authority (for additional details, please visit afca.org.au).
In cases where your complaint pertains to the correction of your credit-related information and the resolution necessitates corrective actions on our part, we will inform every other credit provider and credit reporting body to whom we have previously disclosed this information that you filed a correction complaint. We will also inform these entities of the resolution to your correction request. However, if it is impractical or prohibited by law to provide this notification, we are not legally bound to do so.
14. Financial Institutions To obtain comprehensive details regarding the data collection, retention, utilization, and disclosure practices of the financial institutions, we recommend referring to their respective privacy policies, accessible through the websites listed in the table below. These policies also outline the procedures for accessing and rectifying the information held by these financial institutions and lodging complaints about their data handling. The financial institutions on the Cash Store lending panel encompass a variety of entities, including those mentioned below:
Green Light Auto Group Pty Limited (ABN 39 131 507 474)
https://greenlightauto.finance/
NOW Finance (ACN 158 703 612)
https://nowfinance.com.au/privacy
Firstmac Limited (ABN 59 094 145 963)
https://www.firstmac.com.au/privacy-policy
Plenti Australia RE Limited (ABN 571 666 466 35)
https://www.plenti.com.au/privacy-policy/
Latitude Finance (ABN 42 008 583 588)
https://www.latitudefinancial.com.au/privacy/
Macquarie Leasing Pty Limited (ABN 38 002 674 982)
https://www.macquarie.com/au/about/disclosures/privacy-and-cookies
Pepper Money Limited (ABN 55 094 317 665)
https://www.pepper.com.au/privacy-policy
Westpac (ABN 33 007 457 141)
https://www.westpac.com.au/privacy/
Bank of Queensland Limited (ABN 32 009 656 740)
https://www.boq.com.au/important-information#privacypolicy
ANZ (ABN 11 005 357 522)
https://www.anz.com.au/privacy/centre/policy/
Liberty Financial Pty Limited (ABN 55 077 248 983)
https://www.liberty.com.au/disclosures/privacy-policy
Finance One (ABN 80 139 719 903)
https://financeone.com.au/legal/privacy-statement
15. How to Reach Us If you have inquiries about this policy, concerns, or wish to file a complaint related to the handling of your privacy or a potential breach of your privacy, kindly utilize the contact link on our website or get in touch with our Compliance Officer using the contact information provided below. We will maintain the confidentiality of your requests or complaints. Upon receiving your complaint, our representative will promptly contact you to discuss your concerns and offer potential resolution options. Our goal is to ensure that your complaint is addressed in a timely and appropriate manner.
Please reach out to our Compliance Officer at:
Mailing Address: Compliance Officer Cash Store PO Box 114 South Melbourne, VIC, 3205 Phone: 0433 946 979 Email: geelong@cashstores.com.au
16. Revisions to Our Privacy and Credit Reporting Policy We reserve the right to make revisions to this privacy and credit reporting policy as needed. Any updated versions of this policy will be published on our website and will be effective as of the date of publication. The last update to this policy occurred on Oct11, 2023.