- Who We Are And What This Policy Is About
HEE specialises in leasing household goods to consumers. In the process of providing you with leasing services, HEE may collect, receive, deal with and store your Personal Information and Credit Eligibility Information.
HEE is committed to protecting and maintaining the privacy, accuracy and security of your Personal Information it collects, receives and discloses and is committed to doing so in accordance with the requirements of the Privacy Act (Cth) 1988 (Privacy Act), as amended from time to time.
This Policy describes our commitment in relation to protecting your privacy.
- What Information Does This Policy Apply To?
This Policy only applies to:
- Personal Information;
- Credit Eligible Information; and
- Credit Information.
These items are defined in the Privacy Act.
Generally speaking, Personal Information is information (or opinion), in any form, about an individual (not a business, company or trust) whose identity is apparent or can be ascertained from the information held whether the information is true or not.
Credit Eligibility Information means information we collect from a CRB or that has been derived from information that is about the individual’s consumer and/or commercial credit worthiness.
Credit Information means information that includes the following.
- Information about an individual, such as their name and address that we may use to identify that individual.
- Information about an individual’s current or terminated consumer credit accounts and from 12 March 2014, an individual’s repayment history.
- The type and amount of credit applied for in any previous consumer or commercial credit applications to any credit provider, where that credit provider has requested information.
- Information about an individual from a CRB.
- Information about consumer and/or commercial credit payments overdue for at least 60 days and for which collection action has started.
- Advice that payments that were previously notified to a CRB as overdue or no longer overdue.
- Information about new credit arrangements an individual may have made with a credit provider, in relation to consumer credit currently or previously held, to deal with any defaults or serious credit infringements by that individual.
- Information about the individual’s consumer and or commercial credit worthiness.
- Information about court judgments which relate to judgments relating to credit that an individual has obtained or applied for.
- Information about an individual on the national Personal Insolvency Index.
- Publicly available information about an individual’s credit worthiness, and an opinion of a credit provider that an individual has committed a serious credit infringement of credit provided by that credit provider.
Credit Related Information – for the purpose of this Policy, Credit Related Information includes, as relevant, any information we collect, store, use or disclose out of Personal Information, Credit Eligibility Information and Credit Information.
- Our General Commitment
HEE undertakes to collect, store and use Credit Related Information only in a manner which is compliant with the Privacy Act.
HEE will not use or disclose Credit Related Information other than for:
- for a purpose for which the information was provided;
- for a purpose required or permitted by law;
- a purpose you authorised or that is disclosed to you; and
- to give effect to your instructions.
HEE may collect, store and or disclose information about you to third parties for the following purposes:
- to comply with the law;
- to obtain a credit report about you;
- to allow the CRB to create or maintain a credit information file containing information about you;
- to provide you with promotional information about financial services and products we may provide (see Section 7);
- to manage and administer the agreement with you;
- to protect our lawful interests;
- to give effect to your instructions; and
- if we negotiate with a third party the possibility of an acquisition of part or the whole of our business.
- Credit Reporting Body
We collect, hold and use, information related to your commercial and consumer creditworthiness from a Credit Reporting Body (“CRB”) in order to assist us to produce our own assessments and ratings in respect of your credit worthiness, which may also take into account information we obtain from you and other sources. The reports will have Credit Information from your credit file.
We also disclose information to the CRB. This activity is conducted for the purpose of assessing your credit capacity, eligibility or history in connection with an application or an obligation as a guarantor, collecting payments from you, and managing our credit relationship. Creditworthiness information includes information that is both positive (like payment information) and negative (like defaults or serious credit infringements that we may disclose to CRB’s if you fail to pay us). If you are in default (for an amount exceeding $150 and over 60 days overdue), we may report the default to the CRB in compliance with the Privacy Act 1988.
- Our Collection and Disclosure of Personal Information
HEE collects and discloses Credit Related Information as it may become necessary to process your application and give effect to your instructions.
The information we may collect, hold or disclose includes, when permitted by law:
- identification information, such as:
- your name;
- current and previous address details;
- date of birth;
- marital status;
- government identifiers such as driver’s licence number (see Clause 11);
- email address and telephone/mobile numbers;
- financial information (including credit history), bank account and/or credit card details and personal references;
- current and previous place of employment, employer’s address and contact details;
- the fact that you have applied for credit, the type of credit and the amount;
- whether repayments are more than 60 days overdue;
- the fact that any overdue payments are no longer overdue or a default is remedied;
- whether you have committed a serious credit infringement (ie, acted fraudulently or shown an intention not to comply with your credit obligations);
- information about dishonoured cheques;
- repayment history;
- information about court judgments against you;
- any information which is publicly available and relevant to your credit worthiness;
- certain insolvency information from the National Personal Insolvency Index.
- How We Collect Personal Information
We collect personal information in a variety of ways. Mainly, we will collect information from you when you knowingly provide it to us by telephone, in person or in documentation such as an application form (which may be an online application). We also collect information when you make a request or enquiry of us. We may also collect personal information from publicly available sources or third parties, such as a referee provided by you, a CRB or other credit provider.
- Why We Collect, Hold, Use and Disclose Personal Information
We collect, hold, use and disclose personal information about individuals when it is necessary for us to carry on our business functions or to comply with laws. Importantly, in some circumstances if you do not provide the information that we request, we may not be able to provide our services to you or provide them to the same standard. We may collect, hold, use and disclose your personal information to answer your enquiry and/or provide the information or service that you requested. We may also collect, hold, use and disclose your personal information:
- to enable us to develop, administer and manage our services and businesses;
- to customise services to better meet your needs and preferences;
- to assess your application and manage your account with us;
- to compile a customer profile about you to serve you better;
- to engage a CRB to conduct a credit and reference check;
- to assess your creditworthiness;
- for billing purposes and collection of debts;
- statistical purposes;
- future promotional and marketing purposes including direct marketing purposes;
- to inform you of special offers, promotions and competitions;
- for research purposes to better improve our websites, products or services;
- any other customer support purposes;
- to notify credit providers of a default by you of your agreement with us;
- to advise credit providers of the status of your agreement with us, in circumstances where you are in default with credit providers;
- to deal with complaints;
- to enforce our rights when you are in breach; and
- when authorised or required by law, such laws including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and the National Consumer Credit Protection Act 2009 (Cth).
- Third Parties
Subject to the Privacy Act, in the process of providing you with the services, we may share, as relevant, Credit Related Information with related bodies corporate and with third parties with whom we have dealings in the usual course of carrying on our business. These third party service providers may include agents, mailhouse operators, collection agencies, research providers, dispute resolution schemes, accounting and legal advisers.
We may disclose your Credit Related Information to other organisations, for example:
- Our related companies.
- External organisations that are our assignees, agents or contractors.
- External service providers to us, such as organisations which we use to verify your identity, payment systems operators, mailing houses and research consultants.
- CRB’s, including disclosing that you are in default under a credit agreement (for an amount exceeding $150 and over 60 days overdue) or commit a serious credit infringement.
- Debt collection agencies, if you have not repaid a loan as required.
- Our professional advisors, such as accountants, lawyers and auditors.
- Your representative, for example, lawyer, financial advisor or attorney as authorised by you, or if required or authorised by law, to government and regulatory authorities.
If we disclose Credit Related Information to third parties, we will ensure that these organisations are bound by similar (but not necessarily the same) framework of privacy protection as the framework that governs us.
You have the right to seek access to any information we hold about you. Contact your lessor in this regard. We may charge you a fee to access and or correct your Personal Information that is held with us. You have the right to ask us to correct any information we hold about you if the information is inaccurate or erroneous
HEE maintains strict procedures and standards and takes all reasonable care to prevent unauthorised access to, and modification and disclosure of, your Personal Information.
HEE will protect any Credit Related Information it holds against misuse or loss. If we no longer need the Personal Information, we will take steps to either destroy the information or de-identify it.
- Government Identifiers
HEE does not have access to any Personal Information that can be regarded as or be used as an identifier. For example, HEE does not have access to your Medicare number or tax file number. HEE will not use any government identifier that was disclosed to us (such as driver’s licence number) to identify you.
If you believe that your Personal Information has been mishandled by us or that we have breached this Policy in any way, we invite you to write to our Privacy Officer at email@example.com. We will make every effort to resolve your complaint internally.
If you are dissatisfied with the resolution we offer you, you may access our external dispute resolution scheme, the Financial Ombudsman Service Limited:
Financial Ombudsman Service Limited
GPO Box 3
Melbourne VIC 3000
1300 780 808
- Overseas Entities
It is not likely that we will disclose Credit Related Information to overseas entities. If we disclose Credit Related Information to overseas entities, we will provide details on our website detailing the entities and countries where the information will be disclosed to. We will ensure that they protect the privacy of your Credit Related Information as we are committed under this Policy and the Privacy Act.
When you use our website, we may collect statistical data in relation to your use of the site. This data includes the time and date of the visit to the site, the nature of the inquiry and any documents loaded. We may record your browser type and other internet protocols as permitted.
If you disclosed any Personal Information on the site, the information will be governed under this Policy. The use of public internet public access to our website is not without risk. If you transmit Personal Information via the internet you should ensure that the transmission is secured.
- More Information?
Policy Effective Date: November 2015