Credit Simple recognises the importance of protecting Personal Information about individuals. This Privacy Policy explains how Credit Simple collects, uses and discloses your Personal Information. It also explains how your Personal Information may be used by our Related Bodies Corporate. This Privacy Policy does not limit your rights nor our obligations under Privacy Laws, but provides a statement as to how Credit Simple deals with Personal Information in compliance with Privacy Laws.
Personal Information about you may be collected by Credit Simple when you use the Website or Service through an internet browser, mobile devices, or through the Credit Simple App.
Credit Simple may provide the Services to you directly (via the Credit Simple website and or App) or on behalf of a Customer through a Customer Website. Not all Credit Simple Services may be available to you through a Customer Website. For example, the Credit Simple App is not available to users of a Customer Website. Please refer to the Customer Website Terms of Use to see what Services are available to you.
- Introduction
- 1.1 This Privacy Policy sets out how your Personal Information may be collected, used, stored and disclosed by us, including where you appoint us (as an Access Seeker) to request information about you, on your behalf, from a Credit Reporting Body. By accessing the Website, installing the Credit Simple App and/or using our Services you agree to the terms of this Privacy Policy.
- 1.2 Capitalised terms used in this Privacy Policy have the meaning given to them in clause 14.
- Changing this Privacy Policy
- 2.1 This Privacy Policy may be amended from time to time, by publishing an updated Privacy Policy on the Website and/or the Credit Simple App. We will notify you using the email that you have provided to us of any material changes to this Privacy Policy. Any subsequent access to or use by you of the Website or App will constitute an acceptance of the amended Privacy Policy. You should check from time to time to see if any part of this Privacy Policy has been updated (for example by checking when this Privacy Policy was last updated).
- 2.2 This Privacy Policy does not limit your rights under the relevant Privacy Laws.
- Personal Information we collect
- 3.1 We may collect the following Personal Information from or about you, where the information is reasonably necessary for our business purposes, including to provide our Services to you:
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- (a) name, gender and date of birth
- (b) driver’s licence or passport details, and Medicare card details
- (c) phone number, email address, residential address and previous address
- (d) credit information that may be relevant to a correction request or a complaint that is raised through the Website or
- (e) credit information that may be relevant to us, as an Access Seeker, being able to provide you with a selection of offers based on your request and consent to do so
- (f) any other information that you provide to us or authorise us to collect in connection with a specific service offered on the Website.
- (g) information about your use of the Services, including the dates on which and the times at which you use the Services and the duration of such use, the IP address and/or the MAC address of your computer and/or mobile device, device identifiers, the type of operating system and/or other software or firmware used by your computer or mobile device, and your location information, to understand how you use the Services and to improve the Services.
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- 3.2 If you use the Credit Simple App, you will be able to access the App using Face ID and Touch ID (where available on your mobile device). We do not collect or store any of your Personal Information related to your use of Face ID or Touch ID.
- 3.3 If you access any of our services through a social network site or login to the Credit Simple Website using your social network credentials such as Facebook, Google, or Twitter (Twitter login is not available to new members), we may collect limited information provided to us by that social network site, such as your email address and profile picture.
- 3.1 We may collect the following Personal Information from or about you, where the information is reasonably necessary for our business purposes, including to provide our Services to you:
- How we collect your Personal Information
- 4.1 Personal Information about you may be collected by us in a number of circumstances, including if you: (a) download and install the Credit Simple App; commence the registration process, register or create an account on the Website or App; (b) use our Services on the Website or App; (c) lodge an enquiry with us on the Website, by email or telephone; (d) complete any surveys that we issue or enter into any competitions or promotions that we run; or (e) contact us for any reason, including with support queries.
- 4.2 We collect Personal Information from you directly, unless it is unreasonable or impracticable to do so or if we collect it from the following:
- (a) Third parties that support our Services – we may collect Personal Information from the following third parties: (i) a Credit Reporting Body (on your behalf as an Access Seeker); (ii) suppliers who supply services to us; (iii) our referrers and advertisers; (iv) social media service providers when you log into the Website using your social networking site account (where available); and (v) publicly maintained records;
- (b) Bank(s) – Money Simple enables you to access information relating to all of your chosen Banks in one place. If you use Money Simple on the Website or App, in order to make this Service efficient, Credit Simple and/or illion Open Data Solutions (one of our Related Bodies Corporate) may collect all information available from your Bank(s) using your Bank credentials (even if you only request to see part of that information at any particular time, for example, by selecting a specific chosen account). The information available from your Bank(s) will automatically be updated on a daily basis (except as described below) even if you do not log into your account on the Website or App. If any of your Bank accounts require multi-factor authentication (which is currently only supported on the Website), your information from those Bank accounts will only be updated each time you authenticate yourself on the Website, using the individual authentication requirements of the relevant bank.
- (c) Related Bodies Corporate – We may access Personal Information from our Related Bodies Corporate: (i) in order to enhance the Services we provide to you; (ii) for Marketing Communications, if you opt in (see clause 7 below); or (iii) to receive specialised services in connection with the Services that we provide to you.
- 4.3 We also collect, use, store and disclose non-identifiable information relating to your use of the Website and our Services.
- Purpose of collection of Personal Information
- 5.1 Primary purpose: We collect Personal Information for the primary purpose of being able to operate our business, including to provide our Services to you. If you do not provide all of the Personal Information we request (or authorise us to collect that information), you may not be able to use our Services. Collection of Personal Information for the primary purpose of the Services includes:
- (a) when you register for an account on the Website or App to assess, process and manage your application to use our services – including for identity verification purposes (this includes utilising the services of and providing those services to an identity verification service provider and providing identity verification information to a Credit Reporting Body);
- (b) to enable you to get your credit score and other Credit Information from a Credit Reporting Body;
- (c) to enable you to request a Credit Reporting Body to correct and/or update the Credit Information it holds about you;
- (d) if you use Credit Simple for Business, to verify whether you are a director of a registered Australian company in order to notify you, and confirm, that you are eligible to use Credit Simple for Business, to enable you to get your Business Credit Information from a Credit Reporting Body;
- (e) to assist you to obtain information from credit and or service providers where permitted by you; and
- (f) to enable you to see your chosen Bank accounts in one place, if you use Money Simple
- 5.2 Additional purposes: In addition to those above, we collect Personal Information so that we can carry out the following actions:
- (a) to provide you with a more targeted experience when you use our Services;
- (b) to validate, update and/or enhance our products, services and databases (including those of our Related Bodies Corporate);
- (c) to undertake research, analytics and/or benchmarking;
- (d) to identify and understand user needs;
- (e) to connect future publicly available data sets into our services;
- (f) for our business development and marketing purposes – for example, see clause 7 below;
- (g) if you opt in, to send to you, and display on the Website and App details about products and services and special offers that might interest you based on your credit score and other credit information – see clause 7 below;
(h) prompt you to review your consents, including consents to utilise your personal and Credit Information, are still valid. - (i) to send you alerts and other factual information and updates, (as discussed further in section 7.4 below);
- (j) for any other purpose you have consented to or which is permitted under the Privacy Laws; and
- (k) for internal record keeping, audit and compliance purposes and to comply with our legal and regulatory obligations; and
- (l) if you access the Services through a Customer Website, to provide our Customers with information on your use of the Services.
- 5.1 Primary purpose: We collect Personal Information for the primary purpose of being able to operate our business, including to provide our Services to you. If you do not provide all of the Personal Information we request (or authorise us to collect that information), you may not be able to use our Services. Collection of Personal Information for the primary purpose of the Services includes:
- Disclosure of Personal Information
- 6.1 You authorise us to disclose Personal Information to any of our Related Bodies Corporates for the purposes set out in clause 5. In addition, we may disclose Personal Information to:
- (a) Credit Reporting Body – if you request your credit score or other Credit Information using the Services – refer to clause 6.2 below;
- (b) illion Open Data Solutions – if you use Money Simple Services – refer to clause 6.3 below;
- (c) Customer – if you are accessing the Services through a Customer Website, you acknowledge and agree that we may disclose the following information to the Customer:
- (A) your title, name, address, date of birth and contact details;
- (B) information about your use of the Services, including the dates on which and the times at which you use the Services and the duration of such use, the IP address and the MAC address of your computer or mobile device, the type of operating system and/or other software or firmware used by your computer or mobile device, and your location information,
- (C) any other Personal Information that you have given consent to us to be to be shared with the Customer,
- in order to provide the Services to you, to improve our Services, and for marketing and reporting purposes.
We will share your Credit Information or information collected from your Bank accounts with the Customer only where we have your consent to do so. We do not share your Login Credentials or Bank credentials with Customers.
We may provide the Customer with information that has been de-identified, and/or aggregated in such a way that it cannot be used to identify you.You may choose to provide Personal Information directly to the Customer in connection with the Services. Any Personal Information provided will be handled in accordance with the Customer’s Privacy Policy.
- (d) Our service providers – such as identity verification service providers, Google Analytics (refer to clause 6.4 below), IT suppliers/contractors, identity theft monitoring service providers, call centres, stationery printing houses, mail houses, storage facilities, lawyers, accountants, auditors, and other service providers who need to have access to your Personal Information to provide their services to us;
- (e) Organisations that provide products or services used or marketed by the Website – including intermediaries, trustee companies, financial institutions and securitisers;
- (f) Other – (i) our employees or contractors to the extent reasonably necessary to provide the Website, App and Services and to fulfil our obligations to you and our Customer; (ii) anyone considering acquiring an interest in our business or assets; (iii) other entities or persons to the extent reasonably necessary for the purposes set out in clause 5 above; (iv) any law enforcement, legal, government or regulatory agency, where such disclosure is required or authorised by law; and (v) other individuals or companies authorised by you.
- 6.2 Credit Reporting Body – By requesting access to your Credit Information using the Website or App (or, if you use Credit Simple for Business, to credit information about any company that you are a director of), you also acknowledge and agree that we may disclose your identity verification information and contact details to a Credit Reporting Body. The relevant Credit Reporting Body may use that information to update or correct information held by it and to provide its credit reporting services. The collection, use, storage and disclosure of Personal Information by a Credit Reporting Body, and your rights to request access to and correction of that information, is subject to the Credit Reporting Body’s privacy policy. For more information about how a Credit Reporting Body may collect, use, store and disclose your Personal Information, please refer to the Privacy Policy at https://www.illion.com.au/privacy-policy-risk-marketing-solutions/.
- 6.3 illion Open Data Solutions – If you use Money Simple, you authorise us to disclose your Money Simple Information to, and to collect your Money Simple Information from, illion Open Data Solutions and you authorise illion Open Data Solutions to use your Money Simple Information in accordance with illion Open Data Solutions’ Privacy Policy available at https://www.illion.com.au/privacy-policy-risk-marketing-solutions/.
- 6.4 Third Party Analytics – We use Google Analytics to gather, collect and analyse the activities of visitors and users of our Website and App in order to conduct research and analysis to improve our products, services, and content. You authorise the use of cookies and other tracking technologies to enable Google Analytics and App Analytics to understand visitor or user behaviour on the Website or App. Such access to and use of information collected by Google and Apple are governed by Google’s Privacy Policy and Apple’s Privacy Policy.
- 6.5 Providers and credit providers – You may choose to provide Personal Information directly to any Provider (such as a credit provider), including as a result of using a link from the Website or App to a Provider’s website. If you do so, the collection, use, storage and disclosure of that information by the relevant Provider will be subject to the Provider’s privacy policy and terms and conditions.
- 6.6 Linked Sites – The Website or App may link directly to websites operated by third parties (Linked Sites). You acknowledge that Linked Sites are not operated by us. We are not responsible for the content or practice of the Linked Sites or their privacy policies regarding the collection, storage, use and sharing of your Personal Information. We encourage you to always read the applicable privacy policy and terms and conditions of any Linked Site.
- 6.7 You acknowledge that we do not control and are not responsible for any use of Personal Information by any third party, a Provider, or a Customer that you disclose, or authorise us to disclose, your Personal Information to.
- 6.1 You authorise us to disclose Personal Information to any of our Related Bodies Corporates for the purposes set out in clause 5. In addition, we may disclose Personal Information to:
- Direct Marketing
From time to time we may use your Personal Information which we hold to provide you with:- 7.1 current information about our services, informative articles, promotions, offers you may find of interest, changes to our organisation, or new products or services being offered by us, the Customer, or a third party (Marketing Communications).
- 7.2 By providing us with your Personal Information, you consent to us (including our Related Bodies Corporate) using your information to contact you on an ongoing basis for these purposes, including by mail, email, SMS, telephone and other electronic means.
- 7.3 If you do not wish to receive any Marketing Communications, you may at any time unsubscribe from receiving Marketing Communications by responding via the channel in which you received the Marketing Communication or by visiting the Account Settings page to change your preferences within your Credit Simple account. We will not charge you for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity.
7.4 As you appointed us to be your Access Seeker, we will continue to help you to deal with a credit reporting body and credit providers by showing you offers until you revoke your consent for us to do so, by visiting the Account Settings page to change your preferences within Credit Simple. You can change your mind and re-instate your consent the same way. Where you have revoked your consent, we will not provide offers to you other than those based your credit score and demographic information (e.g. which State you are in). We will not charge for giving effect to your request and will take all reasonable steps to meet your request at the earliest possible opportunity. Please note that revoking the consent as per this clause only means that you are revoking consent to us utilising your other credit information to provide offers to you. To revoke consent to receiving any Marketing Communications, please see clause 7.3. Credit Simple provides you with offers based on your credit score and demographic information, and will continue to do so on the website independent of the consents you have provided or not provided as per clauses 7.3 and 7.4. - 7.5 You may receive Credit Information Alerts and Email Address Monitoring Alerts, which will include (as applicable) factual information and updates about your Credit Information, your account with us, and potential compromises (that have been reported to us) of the email address linked to your account with us. These are not Marketing Communications. You acknowledge and agree that even if you opt out of receiving Marketing Communications, we will still send you essential information such as Credit Information Alerts and Privacy and or Terms of Use updates. You can unsubscribe from Email Address Monitoring Alerts and Credit Information Alerts by changing your preferences in the Account Settings on the Website. Please note that unsubscribing from Credit Information Alerts on the Website does not stop in-app notifications about Credit Information changes on the App, or email alerts that we send to you, that are essential information regarding your Personal Credit Information, and information regarding your account and use of the Service.
- 7.6 If you use Money Simple, we will send you Money Simple updates to provide you with factual information and updates about your use of Money Simple and connected financial institutions (Money Simple Updates). If you use Money Simple on the Credit Simple App, you can also set reminder dates so that the Money Simple Updates will include reminder alerts about upcoming payments identified based on your past transactions. These are not Marketing Communications. You acknowledge and agree that even if you opt out of receiving Marketing Communications, Credit Simple may send you Money Simple Updates until you remove your chosen Bank account(s) from Money Simple.
- Sending information overseas
- 8.1 We operate in both Australia and New Zealand so your Personal Information may be accessible in both countries to ensure we are able to provide our services to you.
- 8.2 Personal Information that we collect is either held by us (at our offices in Australia or New Zealand) or on our behalf. Some information we hold may be stored in “the cloud” in databases on our behalf locally or overseas.
- 8.3 Please be aware that where your Personal Information is disclosed to a third party service provider, credit provider or other entity, they also may use cloud based processes located outside of Australia or New Zealand. We do not control where these service providers may allow Personal Information to be accessible including overseas.
- Provision of information about others
- 9.1 Please be aware that the Terms of Use prohibit the use of our Services on behalf of any other person. We will not ask you to provide us with information about someone else. However, if you provide unsolicited Personal Information to us about someone else, you must ensure that you are authorised by the relevant individual to disclose their Personal Information to us for the purpose for which it is provided.
- Use of Cookies
- 10.1 We may use technology known as a “cookie” to collect statistical information about you when using internet browsing, mobile or tablet applications. Cookies are small pieces of information captured when your device is used to access online content. They can record information about your visit to the Website, allowing it to remember you the next time you visit and provide a more meaningful experience.
- 10.2 You can switch off cookies by adjusting the settings on your web browser. If you disable the use of cookies on your web browser or remove or reject specific cookies from the Website or the Linked Sites then you may not be able to gain access to all of the content and facilities on those sites.
- 10.3 We allow advertisers on the Website and their service providers to also use tracking links on the Website to track performance.
- Storage & Security
- 11.1 We will use all reasonable endeavours to keep your Personal Information in a secure environment, however this security cannot be guaranteed. Our procedures are designed to prevent your Personal Information being accessed by unauthorised personnel, lost or misused. If you reasonably believe that there has been unauthorised use or disclosure of your Personal Information, please contact us immediately using the contact details below.
- 11.2 Notwithstanding the reasonable steps taken to keep information secure, breaches may occur. In the event of a security incident we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving Personal Information, and if so, to assess if it is a breach that would require notification. If it is, we will notify affected parties in accordance with Privacy Law requirements.
- Your access to your Personal Information
- 12.1 It is important to our relationship that the Personal Information we hold about you is accurate and up to date.
- 12.2 You may request access to any of the Personal Information we hold about you at any time. To request access to the Personal Information that we hold about you, use the contact details specified below. We may charge a fee for our reasonable costs in retrieving and supplying the information to you.
- 12.3 We will respond to your request within a reasonable period of time and, where reasonable and practicable, grant access to the information in the manner requested. An explanation will be provided to you if we deny you access to your Personal Information we hold.
- 12.4 If you consider that any information we hold about you is incorrect, you should contact us to request that it is updated. Please let us know if there are any changes to the Personal Information you have provided to us. While we take reasonable steps to ensure that the Personal Information held by us is up to date, we will generally rely on you to assist by informing us if the information we hold about you is inaccurate or incomplete.
- Further Information and complaints
- 13.1 You may request further information about the way we manage your Personal Information, including how to access, request deletion, request a correction or lodge a complaint by contacting us using the contact details below.
- 13.2 We will deal with any complaint by investigating the complaint, and providing a response within 30 days, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree an alternative time frame with you.
- 13.3 Please be aware that Credit Simple is a member of the Australian Financial Complaints Authority (AFCA). If you have a complaint with us that remains unresolved you may refer this matter to AFCA.
- Definitions and interpretation
- 14.1 Capitalised terms have the meanings given to them in the Terms of Use unless otherwise defined:
- Credit Simple, we, us, or our means Credit Simple (Australia) Pty Limited (ABN: 14 614 444 790).
- Credit Simple App or App means the Credit Simple mobile app downloaded from the Apple or GooglePlay app stores. The Credit Simple App is not available to users registered on Customer Websites.
- Credit Simple for Business means the service available to directors of companies registered in Australia through the Website or App (if available).
- Credit Simple Website means the website available at https://www.creditsimple.com.au
- Customer means a customer of Credit Simple that has appointed Credit Simple to provide the Services to you on their behalf.
- Customer Website means the website of a Customer through which the Services are provided to you.
- Money Simple means the Service on the Website or App that Credit Simple and/or illion Open Data Solutions (on behalf of Credit Simple) collects Personal Information from your Bank(s) at any time using your Bank credentials (if available).
- Money Simple Information means Personal Information authorised by you to be collected when you use Money Simple.
- Personal Information has the meaning given to the term in the Privacy Act 1988 (Cth) that you provide to Credit Simple or authorise Credit Simple to collect at any time.
Privacy Laws means and includes the Privacy Act 1988 (Cth) and any other applicable privacy laws, including any determination, code or guideline issued under that Act. - Privacy Policy means this privacy policy, as amended from time to time.
- Service has the meaning given to the term under the Services section in the Credit Simple Terms of Use or the Customer Terms of Use (as applicable).
- Terms of Use means the Terms of Use, as amended from time to time available on the Credit Simple Website or Customer Website (as applicable).
- Website means the Credit Simple Website or the Customer Website (as applicable).
- 14.1 Capitalised terms have the meanings given to them in the Terms of Use unless otherwise defined:
- How to contact us
- 15.1 Please contact us on [email protected] if you have any questions about the Services, or this Privacy Policy.