Swoosh (“we”/”us”/”our”) endeavour at all times to comply with the Privacy Act 1988, Australian Privacy Principles and the Credit Information Privacy Code which together will be referred to in this policy as “Australian Privacy Law”
- you apply to us for one of our credit products;
- you receive credit from us; or
- we otherwise hold credit information about you or information about your eligibility for credit or credit worthiness.
What kinds of credit information do we collect, hold, use and disclose?
- Identification information;
Financial Information including
- Income (from all sources including government benefits) and current employment status and recent history;
Consumer credit liability information about the Consumer credit accounts you have applied for or hold whether with us or some other credit provider including:
- type of account;
- when and whether it was opened and, if applicable, closed;
- if a credit account, then the maximum amount of credit approved;
- other specific terms and conditions of the account.
Repayment history information of Consumer credit accounts you now hold or which you have held with us or with some other credit provider including:
- Whether or not payment was made in any month it was due;
- Any late payments;
- When the payment was ultimately paid.
Information about your credit application including:
- The type of credit, whether consumer or commercial;
- The amount of credit sought.
- Whether we made an information request about you to a Credit Reporting Body.
- Default information about you when you have failed to make a payment owed by you to us or some other credit provider which remains overdue for more than 60 days and which, after giving you notice as required by the Australian Privacy Laws, we may disclose to a Credit Reporting Body or which has already been disclosed to a Credit Reporting Body by another credit provider.
- Payment Information which discloses that you have made an overdue payment whether to us or to another credit provider.
- New payment information about you as to the terms and conditions of any variation in the payments required under your Consumer credit contract with us or with another credit provider.
- Court proceedings information about a judgment of any Australian court that was made against you in relation to any credit that was provided to or applied for by you.
- Personal insolvency information which has been recorded in the National Personal Insolvency Index maintained by the Insolvency and Trustee Service of Australia relating to any bankruptcy, debt agreement, debt agreement proposal or a personal insolvency agreement executed by you, and any direction or order made under the Bankruptcy that relates to your property.
- Publicly available information about you that is not otherwise described above but which is relevant to your credit worthiness.
Serious credit infringement information which relates to Consumer credit which we or some other credit provider has provided to you to the effect that you:
- fraudulently obtained Consumer credit;
- fraudulently evaded payments under a Consumer credit contract;
- are not able to be contacted at the last known addresses supplied to us or have not been in contact with us for 6 months; or
- are otherwise no longer intending to comply with your Consumer credit obligations.
- Credit worthiness or credit eligibility information which we derive from the above information to produce tools, such as risk ratings and credit scores, to assist us to assess your application for Consumer credit from us. Such credit worthiness or credit eligibility information may be based on your Financial Information but will not include it in a recognizable form.
How do we collect credit information?
- We collect credit information about you from you directly such as in an application form for Consumer credit; and
- We collect credit information about you from Credit Reporting Bodies; and
- We may collect credit information about you from other credit providers.
How do we hold your credit information?
How do we disclose your credit information?
In order to obtain credit information about you from Credit Reporting Bodies we may be required to disclose to them credit information about you which we hold. Those Credit Reporting Bodies may then include that credit information about you in reports they provide to other credit providers.
We may also disclose your credit information to other credit providers on production of your written consent and at our discretion informed by our obligations under Australian Privacy Law.
This includes all the credit information described above with the exception of your Financial Information. It does, however, particularly include
- Credit worthiness or credit eligibility information;
- Information about your credit application;
- Repayment information;
- Default information; and
- Serious Credit Infringement information.
The Credit Reporting Body/Bodies to which we may disclose your credit information are:
Dunn and Bradstreet (Australia) Pty Ltd
PO Box 7405, St Kilda Road,
MELBOURNE Vic 3004
Veda Advantage Information Services and Solutions Limited
PO Box 964,
NORTH SYDNEY NSW 2059
The purposes for which we collect, hold, use and disclose your credit information
- assess your credit application and that of any proposed guarantors of your Consumer credit;
- manage your credit contract;
- consider any application for variation of your payments whether or not on the grounds of hardship;
- collect any debt or otherwise enforce any rights whether by court proceedings or otherwise arising under your Consumer credit contract;
- assist you if we consider you may be at risk of default;
- participate in the Credit Reporting system and provide information to the Credit Reporting Body/Bodies as described above;
- a prospective purchaser or other entity involved in the sale, transfer or restructure of our business assets;
- Identify you as required by the Anti-Money Laundering/Counter-Terrorism Financing Act;
- meet our legal requirements including those under Australian Privacy Law and other laws to relevant authorities;
- assist other credit providers with the same purposes as permitted by Australian Privacy law such as disclosing credit information to them with your consent or where you have committed a serious credit infringement.
Whether we supply your personal information to overseas recipients.
We shall not provide credit information and credit worthiness or credit eligibility information to overseas entities except as permitted by Australian Privacy Law.
How you may access your credit information held by us
There is no charge to make a request for access to your credit information but we may apply an administration fee for providing access to your credit information.
How you may seek correction of the credit information we hold about you
We will deal with your request according to Australian Privacy Law and provide you our response and/or reasons within 7 business days of our making our decision and, in any case, no later than 30 days after receiving your request.
If we have supplied credit information which we have agreed to correct to a Credit Reporting Body, we will notify that body within 7 business days of making that decision.
How you may complain about how we deal with your credit information
Changes to this policy
If you do not wish to provide personal information to us, then you do not have to do so, however it may affect your use of this Website or any products and services offered on it.
1. What personal information do we collect from you?
General information requested: We may collect personal information from you in the course of our business, including if you input personal information on the Website or otherwise provide personal information, requested by us. This information requested is set out in our requests. It may include your name, address, phone number, email address, and other personal and/or demographic information.
Additional: If we offer additional benefits to you, we may ask you to provide us with your personal information for these purposes. Providing this information is optional to you. If you do not provide this information to us, we may not be able to contact you or give you access to the additional benefits. .
Institution : If you request us to access bank/financial information on your behalf, you will be asked to provide us with the name of your bank/financial institution, and your username and account log in details, so that the bank/financial institution can identify you to access your records and your account log in details.
Payment: If you pay for a service then you need to provide your payment details, for example credit card, debit card or PayPal.
Communication: If you choose to have your bank/financial statement data sent to you, you will need to provide us with an email address.
Opinion: We may conduct surveys or market research to seek your opinion and feedback.
We will not ask you to provide personal information that may disclose your political, religious or philosophical beliefs or affiliations, health and sexuality, racial or ethnic origin, or criminal convictions.
2. How do we use the personal information that we collect?
General: We use certain personal information for purposes including internal record keeping; for business development and marketing purposes; identifying and understanding user needs; to contact you including for market research purposes; for marketing (including direct marketing) communication; and to customise, improve and ensure proper functioning of our Website.
Additional: If we offer additional benefits to you, and you choose to provide additional personal information for these purposes, we may use your personal information to send you promotional information about third parties that we think you may find interesting.
Institution: If you provide us with bank/financial information, we use this to access the bank/financial information that you request us to access on your behalf, from the bank/financial institution that you nominate, for the lender/financial institution that you nominate.
Payment: If you provide us with personal information for payment details, then we will use the personal information for your payment.
3. How do we disclosure your personal information?
General: We customarily do not disclose, or permit the disclosure of your personal information:
(a) in a way that could be used to identify an individual member in any circumstances; or
(b) to unrelated third parties, including to third party recipients overseas;
If there is a change of control of our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser. We would seek to only disclose information in good faith and where we have sought to maintain confidentiality.
Institution: We disclose the bank/financial information that you provide to us (including your username and account log in details) as required to the bank/financial institution to access the information that you request us to access on your behalf.
Payment: We disclose the personal information that you provide to use for payments, as directed by you to process your payment.
4. Your Rights:
6. Storage and Security
General: We are committed to keeping your personal information secure. We take all reasonable steps to ensure that the personal information collected from you is accurate, up to date, complete and stored in a secure environment and accessed only by our authorised personnel. Our service is a read only service. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. User login credentials are not stored in any form. Connections are encrypted using 256-bit encryption with 2048-bit keys. All server login access is monitored. Anomalous and potentially fraudulent activity is detected and logged, and access may be revoked temporarily or permanently.
Transmission: Please note that no information transmitted over the Internet can be guaranteed to be secure. We cannot guarantee the security of any information that you transmit to us, or receive from us. The transmission and exchange of information is carried out at your own risk.
Institution: We will not store your banking username and account log in details. We may store generated bank/financial statements on behalf of the lender/financial institution. We may store anonymous account and transaction data, and other data obtained through your financial institution, in a way which is not personally identifiable, and is encrypted where possible. This data may be used to provide better services to you and other users of our website and service, or to generate anonymous aggregate data.
7. Links to third party websites