We are bound by the Privacy Act 1988 (Cth) (including the Australian Privacy Principles, Credit Reporting and mandatory data breach notification) and the Privacy (Credit Reporting) Code.
that agreement will override this policy.
We are committed to safeguarding the privacy of our website visitors; in this policy we explain how we will treat your personal information.
2. WHAT TYPES OF INFORMATION DO WE COLLECT?
We only ask for personal information relevant to our business relationship with you as a customer.
2.1. PERSONAL INFORMATION
Personal information is information or an opinion about an individual who is identified, or who can reasonably be identified, from the information. When you apply for one of our products or services, we may request:
- Information which identifies you, like your name, address and other contact details and your date of birth;
- Information about your financial position, like your income, expenses, savings and assets and any (other) credit arrangements;
- Your employment details;
- Your tax file number; and
- Your reasons for applying for a product or service.
2.2. CREDIT INFORMATION
Information collected for credit purposes includes some elements of personal information but also includes the following:
- The kinds of credit products you have or have applied for;
- How you’ve managed your credit obligations, such as your repayment history;
- Information about you from a credit reporting body;
- Any information about overdue credit payments, including any defaults or serious credit infringements by you;
- Information about court judgments which relate to credit that an individual has obtained or applied for;
- Information about you on the National Personal Insolvency Index; and
- An opinion of a credit provider that you have seriously failed to meet the requirements of any credit you have borrowed from that credit provider.
2.3. SENSITIVE INFORMATION
Where it is necessary to do so, we may collect personal information about you that is sensitive. Sensitive information includes information about an individual’s health, and membership of a professional or trade association.
Unless we are required or permitted by law to collect sensitive information, we will first obtain your consent.
However, if the information relates directly to your ability to meet financial obligations that you owe to us, you are treated as having consented to its collection.
3.HOW DO WE COLLECT INFORMATION?
3.1. INFORMATION COLLECTED DIRECTLY FROM YOU
Wherever possible, we will collect all information directly from you which will generally come from what you provide in your application for one of our products or services.
Where we communicate with you over the phone we may record those phone calls for training, quality assurance purposes or to maintain a record of your instructions to us.
We will inform you if you are being recorded, and you have the right to request that we do not record you. Please note if you request that we do not record you, we may not be able to discuss any of your personal information over the phone.
3.2. INFORMATION COLLECTED FROM THIRD-PARTIES
We may also collect personal information about you from third parties, such as any referees that you provide, your employer, a referrer who may have referred you to us for a product or service, other credit providers and third party service providers including credit reporting bodies. Credit reporting bodies collect credit information about individuals and companies, which they provide as credit reports to credit providers (like us) and others in the credit industry to assist them in managing credit risk, collecting debts and other related activities.
You can also ask a credit reporting body, through contact details on their website, not to use or disclose your personal information if you believe on reasonable grounds that you have been or are likely to be a victim of fraud, including identity fraud.
3.3. INFORMATION COLLECTED THROUGH OUR WEBSITES
When you visit our websites we will sometimes collect information about your visit to help us to improve the experience you have. This will help us improve and maintain the security measures we have in place, or learn more about you so any marketing we provide you is as relevant as possible. Information we collect for these purposes includes:
- The time and date of the visit;
- Any information or documentation that you download;
- Your browser type;
- What sections of our websites you view and any errors you experience; and
- Internet protocol (IP) details of the device used to access the site.
It is necessary for us to collect your IP address for your interaction with various parts of our website. Your IP address will not be used by us or released to any third party except in the case of security, inappropriate behaviour or fraud issues, such as unauthorised access to your or our computer systems or fraudulent transactions.
Our website also includes a number of calculators, which may require you to enter your personal details. If you save the data you enter on the calculator, this information will be stored.
Please note that unless you log-on to our secure internet banking platform, or contact us using an online form, your visit and any browsing you do on our website will be completely anonymous.
Sometimes we may use an external service to collect the above information and provide us with reports that help us to understand our website’s traffic and webpage usage.
4. USE OF INFORMATION
We may use your personal information for the purpose of providing products and services to you and managing our business. This may include:
- Assessing and processing your application for the products and services we offer;
- Executing your instructions;
- Charging and billing;
- Uses required or authorised by law;
- Research and development;
- Collecting overdue payments due under our credit products;
- Managing our rights and obligations regarding external payment systems; or
- Direct marketing.
In general, we do not use or disclose your information for a purpose other than:
- You would reasonably expect;
- Required or permitted by law; or
- Otherwise disclosed to you to which you have consented.
We may use your information to provide you with information about products and services, including those of third parties, other MyState Limited companies which we consider might be of interest to you.
We may also provide your details to other organisations for specific purposes such as direct marketing, pre-screening for direct marketing and to better understand our customer groups and profiles.
You may opt out at any time if you no longer wish to receive marketing information or do not wish to receive marketing information through a particular channel, like email. You can make this request by contacting or by ‘unsubscribing’ from our email marketing messages, which always include an unsubscribe option.
4.2. CREDIT DIRECT MARKETING
We may use your information for credit direct marketing.
To do this we ask a credit reporting body to “pre-screen” a list of potential recipients of our direct marketing against our eligibility criteria, to remove recipients that do not meet those criteria.
The credit reporting body cannot use information about your existing loans or repayment history in carrying out its pre-screening and it must destroy its pre-screening assessment once it has given us, or a contractor acting on our behalf, the list of eligible recipients.
If you do not want your credit information used for prescreening by a credit reporting body, you can opt-out by informing that credit reporting body. We may disclose information to or collect information from Equifax Inc.
Contact details can be found at www.equifax.com.au
5. WHO WE DISCLOSE YOUR INFORMATION TO
We may disclose your personal information to other organisations, for example:
- Other entities under We Fund Pty Ltd;
- External service providers and any organisations that are our assignees, agents or contractors providing us services including but not limited to verification of identity, payment system operators, mailing houses and research consultants;
- Insurance providers, where insurance is provided in connection with our services to you;
- Superannuation funds, where superannuation services are provided to you;
- Other financial institutions, for example, when you apply for a loan from another credit provider and you agree to us providing information;
- Credit reporting bodies, information including but not limited to repayment history, default history, credit infringement and non-disclosure;
- Providers of professional services such as Loan Mortgage Insurers, collections agencies, lawyers, debt collectors, accountants, etc.;
- State, territory or regulatory authorities as needed;
- Organisations involved in our funding arrangements – including loan purchasers, investors, advisors, researchers, trustees, rating agencies and financial intermediaries;
- Your representative, for example, a lawyer, mortgage broker, financial advisor or attorney, as authorised by you; or
- The issuer of any documents which you provide us with for the purposes of verifying those documents e.g. to verify a drivers licence with the Australian State or Territory who issued it.
We will not directly disclose your personal information overseas, including your credit information. Where we are required to provide your information to other organisations in the provision of services, including but not limited to insurers, lenders’ mortgage insurers or other entities necessary in the provision of our products or services, your personal information may be disclosed by these organisations overseas, including your credit information.
We take all reasonable steps to safeguard your information, held on our websites or otherwise, is protected from:
- Misuse, interference and loss; and
- Unauthorised access, disclosure or modification.
Depending on the type of information, we will sometimes send information to third-party storage providers to hold and keep secure. Where we send your information to a third party, we will take all reasonable measures to make sure your information is protected.
6.1. PHYSICAL INFORMATION SECURITY
Some of the things we do to protect the physical information we hold about you include:
- Endeavouring to keep all data held within Australia;
- Performing customer identification checks before providing any information;
- Providing training to relevant staff on how to manage customer records and information in accordance with this Policy.
6.2. DIGITAL INFORMATION SECURITY
Some of the things we may do to protect the digital information we hold about you include:
- Using up-to-date security measures on our websites to protect your personal information and your credit information;
- Encrypting any data containing personal, credit or related information which we transmit via the internet;
- Performing regular security testing and auditing of our systems used to store your personal information; and
We ask you to keep your passwords and personal identification numbers safe, do not write them down, allow anyone to see you enter your details and do not tell anyone what they are.
6.3. INFORMATION WE DID NOT ASK FOR OR NO LONGER NEED
Where we are given information that we did not ask for, we will only continue to hold the information if we need it. If we decide we do need this information, we will keep it securely along with the rest of your information. If we do not need this information, we will take reasonable steps to destroy or de-identify it.
When we no longer require your information (including when we are no longer required by law to keep records relating to you), we will take reasonable steps to destroy or e-identify it.
6.4. IN THE EVENT OF A DATA BREACH
We are bound by the Privacy Act 1988 and are committed to complying with the Notifiable Data Breaches Scheme (NDB) established by the Privacy Amendment (Notifiable Data Breaches) Act 2017.
The NDB requires that where a data breach is likely to result in serious harm to any individuals to whom the information relates, we are required to notify those individuals and the Office of the Australian Information Commissioner (OAIC).
The NDB will provide greater protection to the personal information of consumers, greater transparency in the way organisations like us respond to data breaches and give individuals the opportunity to minimise the damage caused by any unauthorised use of their personal information.
You have the right to request access to the information that we hold about you at any time. You also have the right to request information that we hold about you be corrected at any time. Requests to access your information can be made by contacting us.
We will respond to your request for access within a reasonable time. If we refuse to give you access to any of your information, we will provide you with reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access. You can contact us if you would like to challenge our decision to refuse access.
There is no charge for making a request to access your information. However, in some cases, there may be a charge to cover the time we spend locating, compiling and explaining the information you ask for. If there is a charge, we will give you an estimate upfront, and confirm that you wish to proceed.
Phone (03) 8840 2488
9. OUR CONTACT DETAILS
Phone (03) 8840 2488
Level 5, 9-11 Cremorne Street Cremorne VIC 3121
10. COMPLAINTS & FEEDBACK
We take your feedback seriously and aim to provide simple, easy to use and trustworthy services to our customers. We see your complaint or feedback as an opportunity to not only resolve the matter for you, but as a way to improve the way we do things.
Make a complaint or provide feedback You can advise us of your complaint or provide feedback by:
- calling us – (03) 8840 2488 (between 9:00am and 5:00pm Monday to Friday, except on public holidays);
- using the online form at wefund.com.au;
- email us – (firstname.lastname@example.org); or
- write to us (Complaints & Feedback, Level 5, 9-11 Cremorne St, Cremorne VIC 3121).
10.1. DETAILS OF YOUR COMPLAINT OR FEEDBACK
So that we can resolve your complaint as quickly as possible, it is important that you provide us with as much information as possible. This includes details such as:
- your customer number and name;
- contact details – preferred contact method; if by phone advise the best times to reach you;
- complaint or feedback information – what is your complaint or feedback about and when did it happen; and
- resolution – how would you like the matter resolved.
We will try our best to resolve the complaint for you on the spot, and in most cases we can. If we can’t we will:
- keep you up to date on our investigation and progress;
- work to resolve your complaint within 21 days of receiving it from you;
- let you know if we need more information or more time to investigate; and
- provide you with final resolution within 45 days – if not we will inform you of the reasons for delay.
If we request further information from you to help us resolve your complaint and you do not respond, we may consider the matter resolved. However, if you provide information at a later date we will reopen the complaint and continue to work on a resolution for you.
10.3. OTHER OPTIONS
If you are not satisfied with our initial response, you can request for your complaint to be reviewed by our External Dispute Resolution Service. We Fund Pty Ltd is a member of the Australian Financial Complaints Authority (AFCA). AFCA is an external dispute resolution body that deal with complaints regarding the financial services industry.
Australian Financial Complaints Authority
Phone 1800 931 678
Mail Australian Financial Complaints Authority, GPO Box 3 Melbourne VIC 3001
Alternatively, you can reach out to the Office of the Australian Information Commissioner who can investigate your complaint. They can be contacted by the privacy hotline 1300 363 992 or at www.oaic.gov.au