Who are we?
‘We’, ‘us’ and ‘our’ refer to Positive Group Australia Pty Ltd (ACN 610 067 715, Australian Credit Licence 484 982) and our related entities Positive Lending Solutions Pty Ltd ABN 62 605 678 813, Nodifi Pty Ltd ABN 19 619 419 028, Positive Home Loans Pty Ltd ABN 58 619 067 715, Positive Wealth Management ABN 46 605 679 178.
Our commitment to protect your privacy
At Positive Group Australia, we understand that the details you provide us are private and personal. It’s important that you feel secure whenever you deal with us. It’s also important that you understand how we protect your privacy and the manner in which we may use your details. As such our policies relating to personal information are designed to ensure that you are fully protected under Australian privacy laws. Our commitment in respect of personal information is to abide by the Australian Privacy Principles for the protection of personal information, as set out in the Privacy Act and any other relevant law.
When we refer to the personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. The personal information we hold about you may also include credit information.
Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history in respect of those loans, and any defaults. Usually, credit information is exchanged between credit and finance providers and credit reporting bodies.
The kinds of personal information we may collect about you include your name, date of birth, address, account details, occupation, and any other information we made need to identify you.
If you are applying for finance we may also collect the ages and number of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings and expenses. If you apply for any insurance product through us we may also collect your health information. We will only collect health information from you with your consent.
As with most online businesses, we may log information about your access and use of our websites, including through the use of internet cookies, your communications with our Websites, the type of browser you are using, the type of device and operating system you are using and the domain name of your internet service provider.
By submitting an enquiry and providing your personal information via our websites or applications, you are consenting to the collection of that information for the uses as described below and s such cannot opt-out of the collection of the information..
Why we collect your personal information
We collect personal information when you apply to join our network or for the purposes of assessing your application for finance and managing that finance. We may also collect your personal information for the purposes of direct marketing and managing our relationship with you. We may sell or otherwise monetise your information to third parties as permitted by law. From time to time we may offer you other products and services.
To enable us to maintain a successful business relationship with you, we may disclose your personal information to other organisations that provide products or services used or marketed by us. We may also disclose your personal information to any other organisation that may have or is considering having an interest in your finance, or in our business.
How do we collect your personal information?
Where reasonable and practical we will collect your personal information directly from you via our websites, apps or telephone. We may also collect your personal information from finance brokers and other people such as accountants and lawyers.
Do we disclose your personal information?
We may disclose your personal information:
to prospective funders or other intermediaries in relation to your finance requirements;
to other organisations that are involved in managing or administering your finance such as third party suppliers, printing and postal services, call centres;
to associated businesses that may want to market products to you;
to companies that provide information and infrastructure systems to us;
to anybody who represents you, such as finance brokers, lawyers and accountants;
to anyone, where you have provided us consent;
to unrelated third parties as permitted by law;
where we are required to do so by law, such as under the Anti-Money or Laundering and Courter Terrorism Financing Act 2006 (Cth);
to investors, agents or advisers, or any entity that has an interest in our business; or
to your employer, referees or identity verification services.
Prior to disclosing any of your personal information to another person or organisation, we will take all reasonable steps to satisfy ourselves that:
the person or organisation has a commitment to protecting your personal information at least equal to our commitment, or
you have consented to us making the disclosure.
We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located outside Australia.
We may disclose your personal information to overseas entities that provide support functions to us. You may obtain more information about these entities by contacting us.
From time to time we may use your personal information to provide you with current information about finance, offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.
If you do not wish to receive marketing information, you may at any time decline to receive such information by telephoning us on 1300 057 085 or by writing to us at firstname.lastname@example.org. If the direct marketing is by email you may also use the unsubscribe function. 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.
Updating your personal information
It is important to us that the personal information we hold about you is accurate and up to date.
During the course of our relationship with you, we may ask you to inform us if any of your personal information has changed.
If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.
Access and correction to your personal information
We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at any time.
We may charge a fee for our costs of retrieving and supplying the information to you.
Depending on the type of request that you make we may respond to your request immediately, otherwise, we usually respond to you within seven days of receiving your request. We may need to contact other entities to properly investigate your request.
There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is vexatious.
An explanation will be provided to you if we deny you access to the personal information we hold about you.
If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information. If appropriate we will correct the personal information. At the time of the request, otherwise, we will provide an initial response to you within seven days of receiving your request. Where reasonable, and after our investigation, we will provide you with details about whether we have corrected the personal information within 30 days.
We may need to consult with other entities as part of our investigation.
If we refuse to correct the personal information we will provide you with our reasons for not correcting the information.
Using government identifiers
If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.
Business without identifying you
In most circumstances, it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information, for example, if you make general inquiries about interest rates or current promotional offers.
We will only collect sensitive information about you with your consent. Sensitive information is personal information that includes information relating to your racial or ethnic origin, political persuasion, memberships in trade or professional associations or trade unions, sexual preferences, criminal record, or health.
How safe and secure is your personal information that we hold?
We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.
Cookies & Web Beacons
We may use web beacons on our websites from time to time. Web beacons or clear .gifs are small pieces of code placed on a web page to monitor the behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
Links to other Websites
If you are dissatisfied with how we have dealt with your personal information, or you have a complaint about our compliance with the Privacy Act, you may contact our complaints officer on 1300 057 085 or by writing to us at email@example.com.
We will acknowledge your complaint within seven days. We will provide you with a decision on your complaint within 30 days.
If you are dissatisfied with the response of our complaints officer you may make a complaint to our External Dispute resolution scheme, Australian Financial Complaints Authority which can be contacted either at www.afca.org.au/make-a-compaint/ or by telephone 1800 931 678 or the Privacy Commissioner which can be contacted on either www.oaic.gov.au or 1300 363 992.
You may request further information about the way we manage your personal information by contacting us.
We are constantly reviewing all of our policies and attempt to keep up to date with market expectations. Technology is constantly changing, as is the law and market place practices.