Protecting personal information has always been important to us. As we operate in Australia, Canada and New Zealand, our privacy obligations are governed by a series of different rules which mean we have further obligations in relation to protecting personal information. We take our obligations pursuant to Australia’s Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth), Privacy Act 1988 (Cth) and the Credit Reporting Code of Conduct ('CRCC'), New Zealand’s Privacy Act 1993 and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA)
This is a summary of our policy on the management, collection, security, integrity, disclosure of and access to personal information about our clients and client's customers; entities that include but are not limited to individuals, companies, trusts, trustees and their assigns ('you') whose personal information we manage, collect, secure, disclose and correct in accordance with our reasonable business purposes. This policy applies to all employees, contractors, partners and directors of the organisation and all personal information held by the organisation relating to its customers. We may change this policy at any time by uploading a revised policy onto the website.
We have a Compliance Department which is responsible for ensuring we comply with our privacy obligations. Every employee is aware of, trained on and responsible for complying with our obligations and are available to respond to any questions you may have. Contact details for our Compliance Department are set out later in this policy document.
| Information | Purpose of collection and disclosure of personal information and how we protect and manage that personal information |
|---|---|
| contact details, date of birth, occupation, driver's license and other identifying information, government services information, financial information, type of consumer credit, day on which the consumer credit is entered into and terminated, the terms and conditions of the consumer credit that relate to the repayment of the amount of credit, the maximum amount of credit available under the consumer credit, repayment history information, transaction history information, default information, serious credit infringement information, court proceeding information and publicly available information. |
If we collect this type of information it is collected for a lawful purpose in accordance with our reasonable business purposes and we will take reasonable steps to ensure you are aware of the collection, why it is collected, who it may be disclosed to and how you can access any personal information we hold. It is generally collected directly from you or from third parties and disclosed to members of our organisation and our clients that may include credit providers and insurers etc. Examples of third party providers of your personal information include:
We may also collect your publicly available information which is collected for the purposes of operating our business, is credit information and relates to credit worthiness, including:
We may also be required to use and disclose your personal information in accordance with the law (for example by direction of a court/tribunal). |
| Unsolicited or sensitive information | We may sometimes collect sensitive information. Sensitive information is only collected if the information is reasonably necessary for the purpose of performing our functions and activities. We will destroy unsolicited information, whether sensitive or otherwise, unless it is necessary for the reasonable purposes of our business. |
| Anonymity or pseudonymity | We will preserve the anonymity or pseudonymity of an individual or entity where practicable in the circumstances and in accordance with the law. |
| Quality of personal information | We will take reasonable steps to maintain accurate and complete personal information. You may access your personal information and request that your personal information is corrected (see below for further details). |
| Direct Marketing | We will not use and/or disclose personal information for any direct marketing purpose without your authority. |
| Government related identifiers | Unless you otherwise authorise us, we will not collect and/or disclose government related identifiers with the exception of those which may be collected in order to accurately identify you. |
| Overseas Disclosure of de-identified information |
Companies or individuals in our organisations or organisations or individuals that support our services and products may be located outside of Australia, Canada and/or New Zealand. This may mean your information is held and processed outside of the country in which you disclosed that information. We disclose information to overseas recipients that is not readily ascertainable and therefore completely de-identified. |
We will take reasonable steps in accordance with the law to ensure the security of your personal information against loss, misuse, unauthorised access, modification and disclosure.
While we take reasonable steps to protect your personal information, if you provide us with personal information the provision of your information is, subject to our obligations at law, at your own risk.
We have appointed specialist service providers for our business such as lawyers, document destruction contractors and external information technology contractors. These service providers are authorised to use personal information maintained by our business to the extent that is necessary for them to provide the contracted services. Our service providers are required to treat that information in the strictest confidence in accordance with confidentiality provisions in our agreements with the service providers and otherwise in accordance with the law.
Cookies may be used by us to collect information including IP addresses about people from our website. There are many aspects of the site which can be viewed without providing personal information, however, for access to future Lead Market customer support features you are required to submit personally identifiable information. Cookies allow us determine who has seen particular pages on our website and how frequently. This can help us to identify your preferences and allow us to recommend content we believe you'd be most interested in or would be most relevant to you.
For each visitor to reach the site, we expressly collect the following non-personally identifiable information, including but not limited to browser type, version and language, operating system, pages viewed while browsing the Site, page access times and referring website address. This collected information is used solely internally for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are at this Site.
You may disable cookies by changing the settings on your browser, although this may mean you cannot use all of the features of our website.
Subject to limited exclusions, you can request access to and correction of your personal information that we hold by contacting us by way of the following methods:
We will endeavour to provide you with the copies of the personal information you require or to correct your personal information within a reasonable time following receipt by us of your request.
If a fee will apply to supply of the information, or we are permitted by law to withhold certain information, or we are unable to correct your personal information, we will advise you as soon as reasonably possible following receipt of your request for that information or correction.
We will destroy personal information upon your request or as required by law. You can contact us 07 3166 8860 or by accessing our website www.leadmarketonline.com. The exception to this is if the personal information is required in order to fulfil the reasonable purposes of our business or the information is required to be maintained and/or stored in accordance with the law.
If you have concerns about how we manage your personal information you may contact our internal dispute resolution team using any of the below methods. We will provide you with an acknowledgement upon receipt of your complaint and seek to resolve it within 45 days (40 in New Zealand).
In the event you are not satisfied with the resolution provided you may escalate your complaint in the relevant country to:
In Australia:
The Information
Commissioner using the OAIC website www.oaic.gov.au or telephone 1300 363 992.
In Canada:
The
Office of the Privacy Commissioner using the website
www.priv.gc.ca or telephone 1800 282 1376
In New Zealand:
The Privacy Commissioner using the Privacy Commissioner website www.privacy.org.nz or telephone 09 302 8680.
