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CITY FINANCE PRIVACY POLICY

AUSTRALIAN PRIVACY PRINCIPLE 1—OPEN AND TRANSPARENT MANAGEMENT OF PERSONAL INFORMATION.

City Finance is committed to protecting your privacy and safeguarding your financial information. Our Privacy Policy describes how we keep this commitment and how we comply with the “National Privacy Principles”, and in particular, the recent amendments introduced by the Privacy Amendment (Enhancing Privacy Protection) Act 2012.

This Privacy Policy covers, inter alia, the following information and considerations:

  • the kinds of personal information that City Finance collects and holds;
  • how City Finance collects and holds personal information;
  • the purposes for which City Finance collects holds, uses and discloses personal

information;

  • how an individual may access personal information about the individual that is held

by City Finance, and seek the correction of such information;

  • how an individual may complain about a breach of the Australian Privacy Principles,

or a registered APP code (if any) that binds the entity, and how the entity will deal with such a complaint; and

  • whether City Finance is likely to disclose personal information to overseas recipients.

If a person or body requests a copy of this privacy policy in a particular form, City Finance will take such steps as are reasonable in the circumstances to give the person or body a copy in the requested form.

City Finance understands and appreciates that you are concerned about your privacy and about the confidentiality and security of information we may gain about you online. City Finance is committed to protecting your privacy. This City Finance Privacy Policy explains how your personal information will be treated. This Privacy Policy applies to all your dealings with us.

However, when dealing with various entities or parts of the website further privacy information may apply in addition to the matters discussed in this Privacy Policy. Accordingly, in addition to the provisions of this Privacy Policy, there may also be specific and additional privacy provisions which apply to certain sections of the City Finance website. Because those specific and additional provisions also relate to your privacy protection, you should review them wherever they are accessible by you on the City Finance website. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

The website and privacy policy is owned and operated by City Finance Australia Pty Ltd ABN 11 602 842 704 domain name www.cityfinance.com.au (“City Finance website”), and is licenced for use and operated in conjunction with the following Franchisee Companies (and other franchisees as from time to time join the franchising network):

Advanced Engineering and Construction Pty Ltd                                    Australian Credit Licence 387574

Australian Money Providers No.2 Pty Ltd                                                 Australian Credit Licence 391934

Buywell Finance Pty Ltd                                                                                  Australian Credit Licence 411995

City Finance Lending Pty Ltd                                                                         Australian Credit Licence 469854

Commercial Equities Pty Ltd                                                                         Australian Credit Licence 411597

Epikdraw Pty Ltd                                                                                               Australian Credit Licence 426741

Future Marketing Pty Ltd                                                                                Australian Credit Licence 413033

Imat Holdings Pty Ltd                                                                                      Australian Credit Licence 390986

Imisides Pty Ltd                                                                                                 Australian Credit Licence 389420

Mike Top & Associates                                                                                    Australian Credit Licence 392396

Razorbay Pty Ltd                                                                                               Australian Credit Licence 411014

Review Finance Pty Ltd                                                                                   Australian Credit Licence 455428

Reefborough Pty Ltd                                                                                        Australian Credit Licence 389952

Shimco Pty Ltd                                                                                                   Australian Credit Licence 467320

Shimtec Pty Ltd                                                                                                  Australian Credit Licence 390591

Sparen Pty Ltd                                                                                                    Australian Credit Licence 388649

 

AUSTRALIAN PRIVACY PRINCIPLE 2 — ANONYMITY AND PSEUDONYMITY

You can deal with City Finance anonymously where it is lawful and reasonably practicable to do so. For example, if you inquire about our loan interest rates or fees and charges on a particular product you do not need to provide your personal details.

AUSTRALIAN PRIVACY PRINCIPLE 3 — COLLECTION OF SOLICITED PERSONAL INFORMATION

City Finance may collect personal information from you in the course of your website or attendance at a branch or by telephone, facsimile or email, due either to the necessity and/or directly related to the loan that you have obtained, are interested in or formally applying. The collection of information will be undertaken lawfully and fairly.

Generally, the information that City Finance collects about you is dependent on how you use the facilities offered by City Finance.

The primary purpose for which we collect personal information, is to either refer your enquiry or enable an assessment to be undertaken for the purposes of providing credit, and otherwise, to provide you with the best service experience possible.

The information collected may include your name, postal or email address, date of birth, financial details, tax file number, health information or other information City Finance considers necessary.

We will, if it is reasonable or practicable to do so, collect your personal information from you directly. This may happen when you fill out a product or service application or an administrative form (e.g. a change of address form) or when you give us personal information over the telephone or counter, or through a City Finance website.

In some instances we collect your personal information from third parties, again, only if it is reasonable or necessary. For example, we may need to collect personal information from a credit reporting agency, your representative (such as a legal adviser), your financial adviser, your employer or publicly available sources of information or any of the other organisations identified below under “Using and Disclosing Your Personal Information”.

If you visit an unsecure area of the City Finance website (that is, an area where you are not required to log on) to read, browse or download information, our system will record the date and time of your visit to our site, the pages viewed and any information downloaded. However, our systems will not record any personally identifiable information within these areas, and after a reasonable period of time that information will be destroyed.

AUSTRALIAN PRIVACY PRINCIPLE 4 DEALING WITH UNSOLICITED PERSONAL INFORMATION

Any unsolicited information of a private nature, however received by City Finance, will be subjected to a determination whether that information is or has been obtained by consent and if not it will be destroyed or de-identified.

AUSTRALIAN PRIVACY PRINCIPLE 5—NOTIFICATION OF THE COLLECTION OF PERSONAL INFORMATION

If we collect or are provided with private information from a third party about another individual and/or if we reasonably believe that a third party is not aware that we have been provided with confidential or private information, we will notify that person or body as to the fact that we have been provided with that information, the City Finance contact details and the circumstances and reasons (if known) of/for the collection of that material along with a copy of this privacy policy.

AUSTRALIAN PRIVACY PRINCIPLE 6—USE OR DISCLOSURE OF PERSONAL INFORMATION

City Finance customarily disclose personal information between City Finance Franchisees and the City Finance Franchisor for the purposes of conducting your loan application, loan monitoring, referral reasons and marketing activities. We will only disclose personal information to an unrelated third party with your consent or pursuant to our obligations under the Anti-Money Laundering and Counter-Terrorism Financing legislation, or as required or authorised by law. Where your personal information is disclosed, we will seek to ensure that the information is held, used or disclosed consistently with the National Privacy Principles, State legislation and other applicable privacy laws and codes.

City Finance may use your personal information and other data provided to us to assess and process your application for our credit product(s) and assist you in obtaining a loan. City Finance may also use your personal information and other data to enhance your experience on its websites, and subject to your consent to transmit marketing communications.

We may also use your personal information and other data for such purposes as processing payments, updating our account records, arranging for your repayments, conducting statistical analysis or feedback purposes.

By completing a City Finance online application, telephone application, face to face application you will be consenting to City Finance contacting Veda Advantage Limited and/or Dun & Bradstreet (Australia) (credit reporting bodies) (contact details below) to confirm your credit status. If you obtain a loan from City Finance, credit information and default listings including a serious credit infringement listing may be passed to the credit reporting body.

The credit reporting body has a credit reporting policy about how they handle your information.  You can obtain a copy of their policy at their website.

Veda Advantage Limited

Dun and Bradstreet (Australia) Pty Ltd

We may also use or disclose the personal information for the following purposes:

  • To enable us to discharge our statutory obligations;
  • To enable us to discharge our contractual obligations when providing services to third parties;
    • To enable the resolution of a concern or complaint such as to a mediator or lawyer; and
    • To provide services.

Contracts we enter into with other parties for the provision of services may require us to disclose your Personal Information to them. In those cases, our contracts require other parties providing services to us to observe the terms of this Privacy Statement. These parties are as follows:

  • third party suppliers, loyalty and affinity program partners, printers, posting services, call centres, and our professional advisers.
  • your financial advisers and their service providers, subject to your direct consent.
  • management advisors and contractors engaged to update our systems.
  • upon the occurrence of a sale of all or part of the assets or business of City Finance to a purchaser.
  • entitles engaged to deal in the payments system including financial institutions, merchants and payment organisations.
  • credit and fraud reporting agencies, debt collection agencies, mortgage insurance companies, your guarantors.
  • Information may be provided to a credit reporting body in relation to consumer credit if there is a failure to meet their payment obligations in relation to consumer credit or commits a serious credit infringement.
  • The credit reporting body that City Finance provides information may use that information to assess the individuals credit worthiness.
  • City Finance will not provide to a credit reporting body information about a payment that this overdue in relation to consumer credit, where the amount of the overdue payment is less than $150.00.
  • City Finance must issue to you the following information/notices under law prior to reporting a default to a credit reporting body:
  • Section 88 notice under the National Consumer Credit Protection Act 2011;
  • a written notice has been given to the customer under section 6Q of the Privacy Amendment (Enhancing Privacy Protection) Bill 2012 (this notice is usually incorporated in the section 88 notice). The amount that is overdue can then be reported to a CRB, but only once that amount is 63 days overdue and subject to a section 21D notice being sent as set out below;
  • a section 21D notice (when the payment remains overdue, and prior to disclosing

default information) and which specifies the amount recorded in the section 6Q notice (less any payments made) is now 60 days overdue. This notice is provided 14 days prior to the listing of the default information:

  • In general a default listing will not occur until 97 days after a default has occurred and the amount owing has been accelerated.
  • A serious credit infringement may be listed after 6 months.

Further information about credit reporting may be found at the Commonwealth Governments OACI site and in particular the Credit Reporting Privacy Code which informs and forms part of this policy:

http://www.oaic.gov.au/images/documents/privacy/applying-privacy-law/privacy-codes/Credit_reporting_privacy_code_as_registered_22_January_2014.pdf

City Finance does no use credit related information from a Credit Reporting Body for the purposes of direct marketing.

Cookies for Internet Website Services

We generally use “cookies” as a fundamental part of our interaction with your Internet browser from any City Finance website. The purpose is to provide you with better and more customised service and with a more effective website.

A “cookie” is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your browser.

City Finance uses cookies for two different purposes. We allocate a cookie to each Internet browser that visits the City Finance website. This cookie does not allow us to collect personally identifiable information about you. We use this cookie:

  1. to allocate an City Finance identification number to your Internet browser (but we cannot identify you from this number);
  2. to determine if you have previously visited the City Finance website;
  3. to identify pages you have accessed and Third Party websites you have accessed; and
  4. for security purposes.

Most of the City Finance website operates by using this type of cookie. Accordingly, if you wish to make full use of the City Finance website, it is required that you accept cookies.

City Finance also uses cookies for secure services (that is, an area where City Finance uses encryption) on the City Finance website. These cookies are used for a variety of purposes, including for security and personalisation reasons. If your browser is configured to reject all cookies you will be unable to use secure services on the City Finance website that require cookies in order to participate.

AUSTRALIAN PRIVACY PRINCIPLE 7—DIRECT MARKETING

We may use or disclose your personal information to let you know about, and develop, products and services from City Finance that might better serve your financial, needs or promotions or other opportunities in which you may be interested. For example, we may do this after an initial marketing contact. You can contact us at any time if you no longer wish us to do so (see the Contacting Us section for more information).

AUSTRALIAN PRIVACY PRINCIPLE 8 — CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION

Because we operate throughout Australia, some of these uses and disclosures may occur outside your State or Territory, accordingly in some circumstances we may require further consents. We do not operate outside of Australia.

AUSTRALIAN PRIVACY PRINCIPLE 9 — ADOPTION, USE OR DISCLOSURE OF GOVERNMENT RELATED IDENTIFIERS

Although in certain circumstances we are required to collect government identifiers such as your tax file number, Medicare number or pension card number, we do not use or disclose this information other than when required or authorised by law or unless you have voluntarily consented to disclose this information to any third party.

AUSTRALIAN PRIVACY PRINCIPLE 10 — QUALITY OF PERSONAL INFORMATION

City Finance will take steps as are reasonable in the circumstances to ensure that the personal information that the entity collects, uses or discloses is accurate, up-to-date and complete and relevant.

AUSTRALIAN PRIVACY PRINCIPLE 11 — SECURITY OF PERSONAL INFORMATION

City Finance stores information in various ways, usually either in paper and electronic form. The security of your personal information is paramount and we endeavour to take all reasonable steps to protect it from misuse and loss and unauthorised access, modification or disclosure.

We have processes in place to ensure the security of your personal information, including encryption of all data when it is transferred to our service providers and limitations on access to personal information within our organisation.

City Finance takes reasonable steps to preserve the security of cookie and personal information in accordance with the City Finance website Terms of Use and this Security and Privacy Statement. If your browser is suitably configured, it will advise you whether the information you are sending us will be secure (encrypted) or not secure (unencrypted).

City Finance regularly reviews developments in security and encryption technologies. Unfortunately, no data transmission over the Internet can be guaranteed as totally secure.

Accordingly, although City Finance strives to protect such information, City Finance cannot ensure or warrant the security of any information you transmit to us or from our online products or services and you do so at your own risk. Once we receive your transmission, we take reasonable steps to preserve the security of the information in our own systems.

How we Handle Email

We will preserve the content of any e-mail that you send us, if we believe that we have a legal requirement to do so. Your e-mail message content may be monitored by our City Finance employees for security issues including where e-mail abuse is suspected; our response to you may be monitored for quality assurance issues.

AUSTRALIAN PRIVACY PRINCIPLE 12 — ACCESS TO PERSONAL INFORMATION

City Finance allows, and is obligated at law in certain instances, to grant access to your personal information upon request. However, this is subject to various exceptions allowed by law such as:

  • access would pose a serious threat to the life or health of any individual;
  • access would have an unreasonable impact on the privacy of others;
  • a frivolous or vexatious request;
  • the information relates to a commercially sensitive decision making process;
  • access would be unlawful;
  • access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function or negotiations with you;
  • legal dispute resolution proceedings;
  • where a third party has given us health information about you in confidence;
  • denying access is required or authorised by or under law.

If an access request is denied, reasons will be provided.

AUSTRALIAN PRIVACY PRINCIPLE 13 — CORRECTION OF PERSONAL INFORMATION

If at any time, you believe that your information is not correct or requires updating please notify us. It is also an obligation in some instances that you maintain the accuracy of your personal information, such as your address and contact details if you have entered into a contract with City Finance.

City Finance will take all reasonable steps to ensure that your privacy details are accurate.

MISCELLANEOUS

Copyright

Copyright in the information contained on this website is owned by City Finance. You may use this information for your own personal reference only. You may reproduce this information in hard copy solely for your personal use. The information may not otherwise be reproduced and must not be distributed or transmitted to any other person or incorporated in any way into another document or other material.

How to contact us about privacy

Your privacy is very important to us. For that reason, please read the following details carefully and get in contact with us if you have any questions.

You can contact us on:

Contact: Privacy Manager

Local Phone: (07) 3458 9200

By Post: PO Box 738, Springwood Qld 4127

Updates to this Privacy Policy

This Privacy Policy will be reviewed from time to time as required or obligated by law.

Dated: 10th October 2016