Privacy and Credit Reporting Policy – WCF Marketing

1. Introduction      

We take our obligations to protect personal information seriously. We are committed to respecting the privacy and protecting the personal information of our users and customers. We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”) (together, the “Privacy Act”), as well as the Credit Reporting Privacy Code. We sometimes handle personal information relying on exemptions under these laws, for example in relation to employee records. Any permitted handling of personal information under such exemptions will take priority over this privacy policy to the extent there is any inconsistency.

This policy provides information as to the kind of personal information that we collect and the ways we use it. In this privacy policy, the terms “we”, “us”, “our” and “WCF Marketing” are references to WCF Marketing Pty Ltd ACN 614 887 875.

WCF Marketing is not a credit provider but can assist you in dealing with credit providers and credit reporting bodies. For example, WCF Marketing can help you get your credit score from a credit reporting body without leaving a ‘footprint’ of the check on your credit history. WCF Marketing can then provide that credit score to NOW FINANCE which can make a tailored credit offer or refer your details to another appropriate credit provider.

The ways in which NOW Finance manages personal and credit related information is detailed in the NOW Finance Privacy & Credit Reporting Policy, which may be found at http://nowfinance.com.au/privacy. “NOW Finance” refers to Now Finance Group Pty Ltd ACN 158 703 612 and in the context of the provision of credit facilities, means Now Finance Group Pty Ltd, Australian Credit Licence number 425142 as agent for NF Finco 2 Pty Ltd ACN 164 213 030.

The term “Website” means the websites under the sub-domain names getmyrate.nowfinance.com.au and getmyrate.pepper.com.au and unless the context requires otherwise, includes any other sites operated by us where this privacy policy is accessible. The term “you”, “your” and “user” refers to you as the user of the Website or our services.

Our contact details are contained in section 7 below.

2. Purpose  

The purpose of this Privacy and Credit Reporting (“Policy”) is to tell you how we manage your personal information, including your credit information and credit eligibility information. This includes the following sections:

  • Collection of Personal Information
  • Dealing with Personal Information
  • Credit Related Information
  • Security, Websites and Cookies
  • Access and Correction of Personal Information
  • Contacts, Feedback and Complaints

You may interact with us anonymously or by using a pseudonym if the interaction is general in nature. However, if the interaction is specific to an account or relates to your personal information we will need to identify you before we engage in further discussions and correspondence.

We may update our Policy from time to time, the updated version will be published on our Website. If you have bookmarked this policy (or the Website) you will need to ensure that the bookmarked version has been updated so that you are aware of the most recent version of this Policy.

3. Collection of Personal Information

3.1 Kinds of Personal Information We Collect

The various type of personal information we collect and hold may vary depending on the nature of our interactions with you.

For example, if you have made an enquiry about obtaining a personalised interest rate with us, we will need to collect and hold your:

  • personal information (eg your full name, address and contact details);
  • credit related information (see section 4 below);
  • credit score from a credit reporting body (note that we collect this on your behalf where you request us to do so);
  • identification information (eg your date of birth and copies of your driver’s license or passport); and
  • employment information.


Sometimes we may collect information that is considered non-personal. This is dealt with in Section 5 below.

In order to satisfy our legal obligations, we may need to retain your information after a transaction or a relationship has ended. However, we will not retain your identifiable personal information longer than is reasonably necessary and permitted under Australian law.

We will only collect sensitive information (e.g. information about your ethnicity, health or biometric information) with your consent or when permissible under Australian law.

3.2 How We Collect Your Personal Information

Where reasonable and practicable to do so, we will generally collect your personal information directly from you or from keeping records of your interactions with us – this may be over the telephone, by email, over the internet, by email or fax, in person or by completion of a form (such as through the Get My Rate page).

Otherwise, we collect information about you from brokers or introducers and others where necessary. For example, we may collect information about you from a credit reporting body as an “access seeker” acting on your behalf under the Privacy Act.

4. Dealing with Personal Information

4.1  How We Hold Your Personal Information

We understand the importance of protecting the personal information we hold about you. We take steps to ensure your personal information is free from misuse, interference, loss, unauthorised access or modification by:

  • securing personal information both in physical and electronic form at our own premises and with the assistance of our service providers;
  • staff education around the importance of privacy and data security;
  • limiting access to personal information only to those that need access; and
  • protecting our systems with appropriate technology solutions.

If you are considering sending us any personal information through the Website or other electronic means, please be aware that the information may be insecure in transit, particularly where no encryption is used (eg email, standard HTTP).

4.2 The Purpose of Collecting, Holding, Using and Disclosing Your Personal Information

The reason we may wish to collect, hold, use and disclose your personal information is so that we can manage and administer the products we provide and to run our business efficiently. You may be an applicant, a current, previous or prospective customer, contractor, job applicant, supplier, partner or party with whom we do or have done business or may do business with in the future.

As a financial services provider, a major purpose for which we collect, hold, use or disclose personal information is to provide you with a tailored personalised interest rate.

Other purposes for which we may collect, hold, use or disclose your personal information include:

  • responding to your queries;
  • assisting you in dealing with credit reporting bodies (eg to obtain your credit score);
  • to pass information about you (upon your instruction) to NOW Finance, and to review or transfer back to you information about estimated interest rates with NOW Finance and other credit providers based on your credit score and other personal information;
  • establishing, managing, administering, evaluating and improving our products or services, including research, planning, service development, security and risk management;
  • identifying you and investigating and protecting ourselves against fraud and unlawful activities;
  • complying with laws which apply to us, assisting regulatory authorities and protecting our lawful interests; and
  • subject to our legal obligations and your requests to opt out, to provide you with promotional information about us and our products on an ongoing basis, by any means including telephone, email and other electronic messages (we may also share your personal information with NOW Finance and our related bodies corporate and joint promotion partners for this purpose).
4.3 Direct Marketing

Personal Information may also be used or disclosed to advise you of products and services that may be of interest to you by means of direct marketing.

If you do not want your personal information to be used for direct marketing purposes, please contact us so that we can action this request. This is referred to as “opting out” of direct marketing. You can “opt-out” of direct marketing by contacting us on the details in section 7 below.

4.4 Disclosure of Personal Information

From time to time and depending on the circumstances, we may share your personal information to our related entities, other businesses who provide services to us and other third parties including:

  • introducers such as brokers, aggregators and partners;
  • service providers such as customer service organisations, call centres, mailing houses, researchers, collections agents, data analysts;
  • other organisations as required or authorised by law, for example, government or regulatory bodies;
  • credit reporting bodies;
  • someone authorised to act on your behalf;
  • a joint applicant on your access seeker enquiry;our professional advisers, including professional service providers (including auditors, insurers and valuers)
  • organisations involved in our funding arrangements such as funders, investors, advisers, trustees and rating agencies;
  • organisations who purchase our debt and to whom we assign our debt to; and
  • organisations wishing to acquire an interest in any part of our business (including its receivables) for assessing or implementing any such acquisition.
4.5 Disclosing Information Overseas

We use overseas service providers for some of our activities and therefore need to disclose personal information to those service providers. Currently, these service providers are located in India, Singapore, Philippines and the United States of America.

5. Credit Related Information

Where you have applied for a personalised interest rate from us, this section will apply in addition to the other sections within this Policy. What this means is that as part of seeking an interest rate from us, we may obtain credit-related information about you from credit reporting bodies.

Credit-related information in this Policy includes:

  • your personal information that has a bearing on credit that has been provided to you or that you have applied for; and
  • credit eligibility information about you that credit reporting bodies derive from the information above, such as credit scores, risk ratings and other evaluations about you.
5.1 Collection, Use and Disclosure of Credit-Related Information

We collect, hold, use and disclose credit information and credit eligibility information about you for purposes reasonably necessary for our business activities and consistently with the requirements in the Privacy Act as permitted by law.

If you apply for a personalised interest rate with us, we may ask for identification information. This could include your name, address, date of birth and drivers’ license number.

Other examples of your credit information and credit eligibility information we may collect, hold, use and disclose include:

  • Your credit score or risk rating;
  • Whether there are any defaults or court judgements listed against you at the credit reporting bureaus;
  • publicly available information relevant to your credit worthiness;
  • certain insolvency information from the National Personal Insolvency Index;
  • information derived by credit reporting bureaus from the above information (eg assessments and ratings in respect of your credit worthiness); and
  • information we derive from the above information (eg our own assessments and ratings in respect of your credit worthiness). This information may include information about your arrangements with other credit providers as well as with us.

The purposes include but aren’t limited to:

  • providing you with a personalised interest rate offer for consumer credit;
  • internal management purposes, including securitisation, risk management, credit scoring and portfolio analysis;
  • to participate in the credit reporting system;
  • undertake securitisation activities and debt assignments;
  • to deal with complaints and legal proceedings;
  • to meet our legal and regulatory requirements (such as reporting matters to regulators or enforcement bodies when authorised or required by law);
  • organisations involved in our securitisation (funding) arrangements performing certain tasks;
  • organisations who purchase our debt and to whom we assign our debt to; and
  • organisations wishing to acquire an interest in any part of our business (including its receivables) for assessing or implementing any such acquisition.

Restrictions apply under the Privacy Act in relation to the circumstances and purposes for which such information may be used or disclosed and we comply with these restrictions. For example, in general, credit eligibility information may not be disclosed unless the recipient is a credit provider and restrictions apply on the use of credit eligibility information for direct marketing.

We may also disclose your credit information relating to your dealings with us to credit reporting bodies (see section 5.2 below). Those credit reporting bodies may include that information in their own records on individuals and also in reports that they share with other credit providers to assist them to assess your credit worthiness.

5.2 Credit Reporting Bodies

We access and disclose credit information to the following credit reporting bodies:

  • Illion (formerly Dun and Bradstreet (Australia) Pty Ltd) 
    Website: www.checkyourcredit.com.au 
    Postal address: PO Box 7405, St Kilda Road, Melbourne, VIC 3004
  • Experian Australia Credit Services Pty Ltd 
    Website: www.experian.com.au 
    Postal address: PO Box 1969, North Sydney, NSW 2060

You can contact these credit reporting bodies or visit their websites to see their policies on the management of your credit related personal information, including details of how to access your credit related personal information they hold.

5.3 Other Rights Regarding your Credit Reporting Information
            5.3.1 Direct Marketing Pre-Screening

You have the right to request these credit reporting bodies to exclude your credit related personal information to determine your eligibility to receive direct marketing from credit providers including us.

            5.3.2 Victim of Fraud

You also have the right to request credit reporting bodies not to use or disclose your  credit related personal information if you believe that you have been, or are likely to be, the victim of fraud (for example, you suspect someone is using your identity details to apply for credit).

6. Security, Websites and Cookies (non personal information)

6.1 Tracking Information on the Web

We collect non personal information about users of the Website, including information on which areas of the Website are most often accessed and how long visitors visit those areas, as well as other information such as browser types and operating systems to help us manage and improve the Website.

We store information that we collect through cookies, log files and / or third party site traffic software to create profiles of users generally.

Cookies

Cookies are packets of information that enable our servers to identify and interact more effectively with users’ computers. We use cookies which enable us to monitor such traffic patterns and to improve users’ future experiences of the Website.

A cookie does not identify the user personally but it does identify their computer. Users can set their browser to notify them when they receive a cookie and this will provide them with an opportunity to accept or reject it in each instance. Rejecting cookies may have the effect of limiting access to parts of the Website.

Cookies used may be “session cookies”, which terminate once a user closes their browser. We also may use “persistent cookies” which is a small piece of text stored on a user’s computer for a defined period of time, after which the cookie is erased.

Other Activities on our Website

Like most standard website services, we use log files. This includes internal protocol (IP) addresses, browser types, internet service provider (ISP), referring / exit pages, platform type, date/time stamp, and number of clicks to analyse trends, administer the Website, track users movement in the aggregate and gather broad demographic information for aggregate use. IP address etc are not linked to personal information.

In some cases third parties may use cookies and other technologies such as web beacons and JavaScript on the Website in connection with online services like banner advertising, website analytics and surveys. This may allow them to collect information about your use of our Website (including your computer’s IP address) which they may store in the United States of America or other countries. The use of these technologies allows them to deliver use of the Website and other websites and provide other services relating to website activity and internet usage. Those third parties may also transfer the information they collect to others where required to do so by law, or where those others process the information on their behalf.

The services we may use from time to time include Google Analytics, Google AdSense, DoubleClick, Yahoo, Adobe and Microsoft. You can find more details in the privacy policies for those services, including information on how to opt-out of certain conduct.

7. Access and Correction of Personal Information

7.1 Access

You are entitled to access the information we hold about you. To make a request to access your personal information we hold, please contact us on the details in section 7 below. We may need to verify your identity so we will need as much detail as you can give us about yourself and the particular information you seek so that we may locate it efficiently.

We will usually provide the information requested within 30 days of receiving your request. If there is a reason to deny your request for access we will advise you of this in writing. Some examples of why we may refuse a request for access include where the information:

  • may pose a threat to the health or safety of an individual or the public;
  • may have an unreasonable impact on the privacy of another individual;
  • is not allowed by law; or
  • may reveal internal information relating to a commercially sensitive decision-making process.

There is no charge to request access to your personal information, however, we may apply an administration fee for providing access in accordance with your request.

7.2 Correction

We aim to hold accurate and up-to-date personal information about you at all times. If you consider that any such information we hold about you is incorrect in any way, you may seek the correction of that information. To seek such a correction please contact us on the details in section 7 below.

In certain situations, we may not agree to a request to correct information we hold about you. If this occurs, we will advise you of this and our reason for not agreeing to the correction request in writing. In response, you may ask us to make a note of your requested correction with the information we hold.

8. Contacts, Feedback and Complaints

If you have any questions, concerns or feedback about privacy, please contact us at:

WCF Marketing Pty Ltd

PO Box 24313, Melbourne VIC 3000

Level 6, 468 St Kilda Road, Melbourne VIC 3000

1300 275 669

disputeresolution@nowfinance.com.au

We take your privacy concerns seriously.

Where you express any concerns that we have mishandled your personal information, failed to comply with the Privacy Act (including credit reporting requirements in Part IIIA) or the Credit Reporting Privacy Code, or interfered with your privacy, please contact us on the details above.

We will respond to let you know who will be handling your matter and when you can expect a further response. We aim to resolve your concerns in a fair and efficient manner.

If you are unsatisfied with our response, or if your complaint remains unresolved, you may refer it to our external dispute resolution scheme, the Australian Financial Complaints Authority (AFCA), which provides a free independent industry dispute resolution service. AFCA’s contact details are:

Australian Financial Complaints Authority
GPO Box 3
Melbourne Victoria Australia 3001
Phone: 1800 931 678
Website: www.afca.org.au

Alternatively, you may refer the matter to the Office of the Australian Information Commissioner (the “OAIC”).

The contact details for the OAIC are:

The Office of the Australian Information Commissioner
GPO Box 2999
Canberra ACT 2601
Australia
Phone: 1300 363 992
Fax: 02 9284 9666
Website: www.oaic.gov.au


Last Revised: Sep 2021