- Liberty Financial Pty Ltd
- Liberty Network Services Pty Ltd
- Secure Funding Pty Ltd
- Liberty Fiduciary Limited
- Assured Credit Management Pty Ltd; and
When this policy or any of our communications with you about privacy uses the words ‘we’, ‘us’, ‘our’ or ‘ours’ or ‘Liberty Group’, this is a reference to all or any one of these companies.
We may amend this policy from time to time to ensure it remains current. We recommend that you check our website regularly for changes to this policy.
We collect and hold personal information about our applicants and potential applicants for our products and services, our customers and business partners, including their personal details, employment information, financial data and lifestyle profiles. When we act as a credit provider, we participate in the credit reporting system and collect information relating to your credit activities. The types of credit information we collect is explained in the Credit Reporting section of this policy. We collect information from you directly when you inquire or apply for a product or service with us and when we speak with you on the phone, from third party brokers if you use one and from our related companies. We also collect information from credit reporting bodies, other credit providers, our related companies with whom you have a relationship, third parties you have identified in your application to us, such as employers or government agencies and from publicly available sources. Once you have a product or service with us we will collate information about your use and management of your account. Our main purposes for collecting your personal information include but are not limited to:
- assessing applications for products and services offered by us;
- managing, varying or enforcing our products held by you;
- letting you know about products and services offered by us or by an organisation that we are associated with that might interest you or meet your financial or health needs;
- complying with our legislative or regulatory requirements including but not limited to our requirement to verify your identity under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and our obligations under the National Consumer Credit Protection Act 2009;
- research and product development; and
- any purpose related to those other purposes.
In some circumstances we may collect sensitive information about you and your family, for example if you are in default under a loan agreement with us due to ill-health or if you apply for an insurance product.
We will only collect personal information from you that is necessary to one or more of our functions and activities. We will only collect personal information from you by lawful and fair means, without being unreasonably intrusive, such as when you complete an application form or respond to some other communication relating to the management of your relationship with us.
If you obtain a car loan with us, we may collect information about you from any driver licensing or vehicle registration authority in Australia including but not limited to Roads and Maritime Services (NSW), Department of Transport (WA), Department of Transport and Main Roads (Qld), Department of Planning, Transport and Infrastructure (SA), Road Transport Authority (ACT), VicRoads (Vic), Department of Transport (NT), and Department of State Growth – Transport (Tas).
Communications between us including by telephonic, electronic and written means, for example, may be kept and recorded for various purposes including but not limited to quality and training. If you do not wish for such communications to be recorded, you should let us know.
In most cases, it is necessary for us to identify you so that we can provide our products and services. However, if it is lawful and practicable, you may have the option of not providing us with your identify information such as in certain instances relating to general enquires about products or services.
Once we collect your personal information we will take reasonable steps to keep it accurate, complete and up-to-date. Your information will be securely stored in hard copy documents and electronically on our servers and databases as well on the servers and databases of third parties who provide services to us.
Use and Disclosure
We will only use your personal information for the main purposes we told you it was needed except where: you give us consent to use your personal information for another purpose; the other purpose is related to the main purpose or it is not unreasonable to expect us to use your personal information for that other purpose; it is permitted or required by law; or we reasonably believe it is necessary on health or public safety grounds to use your personal information for another purpose. We will also use your personal information for the purpose of establishing or defending legal claims and as required for alternative dispute resolution proceedings. We will not adopt as our own any government identifiers that you may provide to us such as TFNs or Medicare numbers.
We may share your personal information with our related companies and third parties with whom we have a business relationship, for example: (i) our funders, account holders and operators, credit reporting bodies, other credit providers, introducers, valuers, insurers, debt collection agencies, debt administrators, government authorities, (ii) organisations involved in processing (including card and PIN producers), managing, insuring or funding credit facilities, (iii) organisations to whom we outsource communications functions such as mailing and printing houses and marketing and media organisations including media or social networking sites; (iv) organisations that provide verification of your identity (for example, we may provide your personal information to Equifax, as an authorised Gateway Service Provider of the Document Verification Service, and request that it be matched to information held by the issuer or official body that records that information); (v) specialist advisers such as accountants and solicitors (both yours and ours), and (vi) our associated organisations so that they may let you know about products and services which might meet your needs.
You accept that not all recipients of your information may have privacy practices equivalent to ours and you consent to the disclosure of your personal information for the purposes we have stated above.
We may also use your personal information to send you marketing materials about products or services we think may benefit you. We may also disclose your personal information to our related companies or associated organisations so that they may send you marketing materials. You may tell us at any time that you do not wish to receive any further marketing materials by sending an email to firstname.lastname@example.org and we will stop sending you such materials unless you later consent to receive such materials.
Disclosure Outside Australia
We will endeavour not to send your personal information overseas however there may be circumstances where it is necessary to do so, such as when we share your information with our service providers who use cloud servers located overseas to store your information or our related entities overseas perform operational or administrative services on our behalf, for example. Unless we reasonably believe that the other country has privacy laws substantially similar to our own or the disclosure is required by law, we will seek your consent before we send your information overseas. The countries in which we may send personal information include but are not limited to New Zealand, the United States, England or those in the European Union.
Access & Correction
You may request access to your personal information at any time. We will respond to you within 30 days of receiving your request.
In most cases we will facilitate access by providing you with copies of or a summary of relevant documents however we may decide that other means of providing you with access are more appropriate based on the circumstances of your request. In most cases, we will charge you a fee of $50 for providing you with access to this information.
We are not required to provide you with access to your personal information in certain circumstances, such as where your request is frivolous or vexatious, or where providing access would unreasonably interfere with another person's privacy, would be a breach of the law, or where the information you request is commercially sensitive or relates to existing or anticipated legal proceedings. If we refuse access we will advise you in writing of our reasons for doing so and the mechanisms available for you to make a complaint.
If you request, or if we believe that the personal information we hold about you is inaccurate, out-of-date, incomplete or misleading, we will take reasonable steps to correct your information. We will respond to your request for correction within a reasonable period of receiving your request. We will not charge you for making a request if we correct your information.
If we have previously disclosed your personal information to another entity, you may request us to notify the other entity of the correction. We will notify the particular entity you have identified in your request provided it is not impracticable or unlawful for us to do so.
If we refuse correction we will advise you in writing of our reasons for doing so and the mechanisms available for you to make a complaint. If we refuse to correct your personal information, you may request that we associate your information with a statement that the information is inaccurate, out-of-date, incomplete or misleading. We will take reasonable steps to associate the statement in an appropriate way.
You may make a request for access or correction by contacting our Privacy Officer on any of the contact points referred to in this policy.
We will take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access. Some of these steps include physical security such as locks and access control to our premises and computer security including requiring passwords and other security measures for accessing our systems and databases, as well as having information security policies that our staff and business partners must follow. You can also help us keep your personal information secure by ensuring that any password you use to access our systems is kept strictly confidential and by logging off when you have finished using a shared computer. We will not be responsible for any access or change made to your personal information occurring as a result of you disclosing your password to a third party or through any unauthorised access.
The types of credit information we collect include but is not limited to:
- identification information such as your name, address, date of birth and employment details;
- default information if you have defaulted in your payment obligations to us or other credit providers or committed a serious credit infringement and information about any subsequent payments or new credit arrangements you enter into;
- consumer credit liability information, including details about credit you have with us and other credit providers;
- repayment history information such as when and how you meet your monthly payment obligations to us and other credit providers; and
- information relating to court proceedings or personal insolvency proceedings and other information relating to your credit history.
When we disclose credit information about you to credit reporting bodies, this credit information may be included in a credit report that credit reporting bodies provide to other credit providers to assist them assess your creditworthiness.
We may use any of Equifax Pty Limited (Equifax), Experian Australian Credit Services Pty Ltd (Experian) DBCC Pty Ltd (Dun & Bradstreet), Tasmanian Collection Service (TCS) and Equifax New Zealand as the credit reporting body or bodies from whom we collect and to whom we disclose credit information from time to time. They may be contacted as follows.
|Credit Reporting Body||Contact Details||Credit Information Policy|
|Equifax and Equifax NZ||www.mycreditfile.com.au
You have the right to contact any of these credit reporting bodies and request that they do not use your information for marketing and related purposes. If you reasonably believe that you have been or are likely to be a victim of fraud, you may contact the credit reporting body and request that they do not use or disclose your information.
We are committed to providing applicants, customers, and other parties whose personal information we hold, a fair and responsible system for the handling of their complaints.
If at any time you have any complaints in relation to privacy, please contact our Privacy Officer at one of the points referred to in this policy. We will seek to address any concerns that you have through our complaints handling processes and in most cases will respond within 30 days of receiving your complaint.
If we are unable to resolve your complaint to your satisfaction you may refer your concerns to the Credit and Investments Ombudsman and following this to the Office of the Australian Information Commissioner.
Privacy Officer Contact Details
Our Privacy Officer may be contacted on:
Privacy Collection Notice
We are committed to the protection of your personal information as set out in the Privacy Act 1988 (the Act). This notice explains how we collect and use your information and who we share it with. It applies to any Liberty Group company who uses your personal information.
What: Information which identifies you and information about your finances and how you use our products and services. This may include information about your financial position and credit history including details of your contractual conduct.
Why: To assess and process your application, manage and if necessary enforce your account, meet your future needs, inform you about products or services offered by us or third parties and for research, marketing and development. We will not be able to process your application and/or provide you with our products and services without this information.
How and Who: We collect information directly from you when you apply for one of our products or services and when we communicate with you. We exchange information about you with brokers if you use one, credit reporting bodies when we request your consumer and commercial credit report to assess your application or if you default or commit a serious credit infringement, third parties who provide information relevant to your application or account, our related companies, other credit providers and third parties named in your application or in your credit report such as your employers, government agencies, referees, accountants, insurers, valuers and lawyers. We also exchange information with organisations which provide us with administrative services connected with your account including arranging, funding, settlement, insurance and risk management services, or organisations which are potentially acquiring your account by way of securitisation. We may also share your information with mercantile agencies and debt administrators. We may disclose your information to your current or prospective guarantor.
Overseas disclosure: We will endeavour not to send your personal information overseas. However, it may be necessary if our service providers use cloud servers located overseas to store your information or if our related entities overseas perform operational or administrative services on our behalf or if they wish to promote their business. The countries where your information may be sent include but is not limited to New Zealand, the United States, England and those in the European Union. If this happens you may lose the protection afforded to your personal information under the Act and any right to seek redress from the overseas recipient. We are not accountable to you for the use of your personal information by any overseas recipient.
Credit reporting: Credit reporting bodies will include the information we provide them in credit reports which we and other credit providers will use to verify your identity and assess your credit worthiness or credit conduct, for example. Our credit reporting policy contains more information about how we collect, manage and share your credit information, the credit reporting bodies we use and your rights in relation to your credit information. Our credit reporting policy is available above or by contacting our Privacy Officer.