Privacy Policy

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Background


At Certegy Ezi-Pay ("we", "us", "our"), it is important to us that we manage your personal information securely and consistently with relevant legislation, including the Privacy Act 1988 (Cth) ("Privacy Act") as amended from time to time and the Credit Reporting Privacy Code (where applicable).

This Privacy Policy explains:

  • the kinds of personal information we collect and hold and the purposes for which we collect, hold, use and disclose personal information;
  • how we manage the personal information that we collect about you;
  • how you can seek access to and correction of that information;
  • if necessary, how you can make a complaint relating to our handling of that information.
This Privacy Policy is not limited to current customers or guarantors of customers (where applicable). It also relates to other individuals who deal with us, whether in relation to the provision of credit or otherwise.

Information we may collect


We will collect certain personal information about you depending on the circumstances in which the product or service is being provided. This information can include the following types of personal information:

  • key personal information such as your name, date of birth, residential address, telephone numbers and email and other electronic addresses;
  • financial and related information such as your occupation, accounts, assets, expenses, income, dependents, and in relation to your employment, financial and business dealings and other relevant events;
  • your transaction history with Certegy Ezi-Pay and its associates or relevant third parties. This information includes products you may have used with us in the past, your payment history, and the capacity in which you have dealt or deal with Certegy Ezi-Pay;
  • other relevant information depending on the circumstances and this may include sensitive information such as health and medical information (e.g. if it is relevant to a hardship request) or other government identifiers (e.g. if relevant to identifying you).

We will also need to collect personal information about you that relates to credit, including information such as account numbers or customer identifier numbers.


Applicability of Privacy Policy to credit related information


The Privacy Act has speific rules about two types of consumer credit related information that we may collect:

  • credit information ("CI") – this type information relates primarily to your credit-related dealings with us. For example identification information, information about your account with us and its status (whether it is still on foot, payment and internal default information), as well as any publicly available information.
  • credit eligibility information ("CEI") – this information is provided to a credit provider by credit reporting bodies ("CRBs"), or derived from it, so it may also include information about your credit related dealings with other credit providers.
We collect and hold CI, but we do not collect CEI from CRBs.

How we collect information


In many circumstances, we will collect the above information primarily from you (or from someone who is representing or assisting you). However, there are certain instances in which we will collect information about you from third parties where it is unreasonable or impracticable to collect it directly from you. For example, where we need to verify information you have provided.


Other third parties that we may collect your information from include:
  • our agents;
  • your employers, accountant, referees, banks, landlords, guarantors, lawyers, financial advisers or others with whom you have previously had dealings;
  • other related entities who may have information about you;
  • in relation to credit information – by contacting other credit providers who may have information about you relevant to us;
  • by accessing information about you that is in the publicly available (e.g. internet sources or through the white pages);
  • your executor, administrator or attorney;
  • service providers to us (including debt collection agencies, introducers, private investigators, professional advisers);
  • professional organisations;
  • public and subscriber only databases;
  • any person considered necessary in our view to execute your instructions; and
  • government authorities.

We may also log information about your access and use of our website for example, through the use of internet cookies and your communication with our website. Our ‘Website Terms of Use’ provides more information on this.


How we hold and protect your personal information


We will hold your personal information in paper or other physical form but it is usually held in electronic form on our systems. Service providers may hold the information for us. Your personal information is protected by various physical, electronic and procedural safeguards. Where a service provider holds your information, we require those service providers to adhere to our approved standards of security and confidentiality to ensure the continuing protection of your personal information.

 

We train staff that handle your personal information to ensure that your personal information is handled appropriately. Our procedures ensure that your personal information is only made available to staff where necessary.

 

We will hold, use and disclose personal information that we collect for as long as is necessary to fulfil the purposes identified in this Privacy Policy, and as otherwise identified to you at the time of collection.


Purposes for which we collect, hold, use and disclose your personal information


Purposes for which we will usually hold, use and disclose your personal information, depending on the circumstances and the nature of the products and services you are obtaining from us, include:

  • in order for us to decide whether to provide a product applied for or service requested (this might include evaluating your credit worthiness);
  • providing our products or services, including related arrangements (e.g. where we provide you with credit to make a purchase, or where our product is a payment service, that includes arranging for the purchase to be paid for or the payment to be made, including providing cheque risk management, acceptance and collection services to our retailers and service providers);
  • managing the products and services the we provide;
  • the ongoing monitoring of credit worthiness;
  • to detect and prevent instances of fraud, unlawful conduct, and other risks to you or our products and services;
  • to ensure fast and accurate approval and processing of payment transactions including via cheque;
  • to assess any insurance risks or claims associated with you or our products or services;
  • dispute and complaint resolution, and assisting other credit providers to do the same;
  • enforcing our rights, including the collection of outstanding payments and where necessary, initiating legal proceedings;
  • undertaking review and maintenance of our systems and infrastructure, undertaking research and development regarding potential products and services;
  • undertaking securitisation activities and other activities relating to funding and capital requirements;
  • enabling our associated entities and selected other entities to promote their products and services to customers;
  • marketing products and services provided by us and our related entities (you can request not to receive direct marketing communications at any time);
  • developing an understanding of the products and services you may be interested in receiving from us and our related entities;
  • compiling statistical data (e.g. credit scoring information);
  • assisting customers in meeting their credit related obligations;
  • enforcing our rights, including debt recovery and other enforcement; and
  • dealing with serious credit infringements, and assisting other credit providers to do the same.
  • complying with various Australian laws which may specifically require us to collect your personal information, and with other regulatory requirements and laws where collecting your information is necessary in order for us to comply with our obligations. Some of the key laws which may apply include:
    • the Anti-Money Laundering and Counter-Terrorism Financing Act;
    • the Personal Property Securities Act, and State and Territory real property and security interests laws;
    • the Financial Sector (Collection of Data) Act;
    • the Corporations Act and other regulatory legislation;
    • the Taxation Administration Act, the Income Tax Assessment Act and other taxation laws.

Disclosing your personal information to third parties (including overseas)


Where the Privacy Act permits it, we may disclose your personal information for the purposes above to third parties including:

  • your co-applicant (if any);
  • related entities based in Australia or overseas;
  • entities that provide services to us such as mailing houses or call centre operators;
  • entities providing other services to us, including legal services, financial services, market research and data providers;
  • our assignees or potential assignees, or where we act as an agent for, or otherwise on behalf of, another person, to the principal or that other person;
  • the supplier of any goods or services financed with credit we provide;
  • retailers, where the payment or credit service provided by us involves payments to the retailer for goods or services to be provided by them;
  • other financial institutions or entities such as banks and credit providers;
  • insurers, assessors, underwriters, brokers and other distributors;
  • government regulatory bodies in Australia and overseas;
  • if appropriate, guarantee or security providers;
  • organisations involved in debt assignment or securitisation arrangements;
  • debt collectors or other enforcement bodies;
  • entities who wish to be involved in our business, or acquire an interest in our business;
  • and
  • third parties you authorise to act on your behalf or that are otherwise connected with you (e.g. your accountant, legal representative or referee).

Some of these entities may not be located in Australia, and may not have an Australian link. For example, we employ service providers in countries such as the Philippines, New Zealand and Ireland.


In addition, some of the retailers we deal with may operate overseas. Therefore, when you ask us to make a payment to or to provide credit for a product or service from such a retailer, we will provide information to that retailer and also to banks and other financial institutions (who may also be overseas), who are involved in processing that payment. These entities are not our service providers, and we do not control how they manage your information.


Your consumer credit related information may be disclosed, where relevant, in many of the circumstances described above.


CRBs and your rights in relation to them


Although the Privacy Act permits us to disclose your credit information to CRBs for certain purposes, and to receive information from them, we no longer do this. However, we will appoint an agent to ensure that any previously listed defaults will be updated with the CRB as required (e.g. when repayments are received). CRBs may include the information provided to them in their reports to other credit providers in order for them to conduct an assessment of your credit worthiness.


The CRB details are:


Dun & Bradstreet
Website: www.checkyourcredit.com.au
Phone: 13 23 33
Address: D&B Public Access Centre, PO Box 7405, St Kilda, VIC 3004

Veda Advantage
Website: www.vedaadvantage.com
Phone: 1300 762 207
Address: Veda Advantage Public Access, PO Box 964, North Sydney, NSW 2059

You are entitled to:
  • “Opt Out” of direct marketing pre screenings: CRBs often use credit information to assist credit providers to market their products and services. If you do not want a credit reporting body to use your credit information in this manner, the Privacy Act gives you the right to request you be excluded from being contacted;
  • request non-disclosure where you believe you have been, or are likely, a victim of fraud: if you believe that you are a victim of fraud, or are likely to be a victim of fraud, then you are entitled, under the Privacy Act, to request that a credit reporting body not use or disclose any of your credit information.

Your ability to access your personal information that we hold (including credit information)


You can access the personal information that we hold about you (including credit information)


You can request access to the personal information we hold about you subject to certain exceptions under the Privacy Act. You are entitled to specify how you wish to access your personal information, so long as this is reasonable and practicable. In order to access your personal information, please contact Certegy Ezi-Pay’s Privacy Officer on 08 8232 2828.


Given that the information we will have is of a sensitive nature, we verify the identity of anyone requesting access to your personal information. This will ensure that we do not provide information to a person who does not have the right to access that information.


We ask that your request for information be as specific as possible so that we can accommodate your request. We will usually provide you with access within thirty (30) days of a request but in some circumstances it may take longer.


Please note, that under Australian law, we are entitled to refuse you access to your information in certain circumstances, including where:

  • access would be unlawful;
  • denying access is required or authorised by or under an Australian law or a court/tribunal order; or
  • access would prejudice enforcement activities or the taking of appropriate action in relation to unlawful activity or serious misconduct.

How you can correct the information we have about you (including credit information)


We take every step that is reasonably practicable to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. The Privacy Act gives you the right to request correction of your personal information. If correction of your personal information is required, please contact Certegy Ezi-Pay’s Privacy Officer on 08 8232 2828.


In the event that we do not agree to your request for correction, we will give you notice of this outlining our reasons and what next steps you can take. You may also request us to associate a statement with that information to the effect that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading so that it is apparent to users of the information


Privacy complaints and disputes


The Privacy Act gives you the right to make a complaint if you believe that we have not complied with our obligations under the Privacy Act. If you believe this to be the case, please contact Certegy Ezi-Pay’s Privacy Officer on 08 8232 2828.


We will aim to respond within seven (7) days of you making your complaint to acknowledge receipt of your complaint. It is our policy to investigate and resolve all complaints (where practicable) within thirty (30) days of receiving the complaint. Where it is a legal requirement to do so, then in the event we need more time to investigate and resolve your complaint, we will notify you as to the reasons why and seek your agreement to extend this thirty (30) day period (if you do not agree, we may then not be able to resolve your complaint).


Please note, where your complaint relates to your credit information, we may consult with third parties where necessary and as permitted under the Privacy Act, to investigate and resolve your complaint.


In the event your complaint is not handled satisfactorily by our Privacy Officer, you can contact Certegy Ezi-Pay’s Customer Service Manager on 08 8232 2828.


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Contacting us


If you wish to find out more or to raise a concern about us, our Privacy Policy or privacy practices, you can contact us on Telephone number 1800 088 151 or write to:


Certegy Ezi-Pay Pty Ltd
GPO Box 1878
Adelaide, SA, 5000

Privacy Policy changes


We may change or update this Privacy Policy from time to time. We suggest that you periodically review this Privacy Policy by checking our website at www.certegyezipay.com.au and clicking on ‘Privacy Policy’ to obtain the most current version. This Privacy Policy was last modified on 16 October 2014.