Who are we?
‘We’, ‘us’ and ‘our’ refer to PEPL Holdings Pty Limited ACN 160 430 179 and our related businesses.
Our commitment to protect your privacy
We recognise that any personal information we collect about you will only be used for the purposes we have collected it or as allowed under the law. It is important to us that you are confident that any personal information we hold about you will be treated in a way which ensures protection of your personal information.
Our commitment in respect of personal information is to abide by the Australian Privacy Principles (APPs) and Part IIIA of the Privacy Act, the Privacy (Credit Reporting) Code 2014 and any other relevant law.
We are not a credit provider but can assist you in dealing with credit providers and credit reporting bodies. We do this by getting your credit-related information as your authorised ‘access seeker’ from a credit reporting body without leaving a ‘footprint’ on your credit file. We can then provide that credit-related information to Pepper Group Pty Ltd ACN 094 317 665 and its related entities (Pepper Money) to determine if Pepper Money can make a tailored credit offer to you, or we may refer your details to another credit provider. The ways in which Pepper Money manages personal and credit related information is detailed in the Pepper Money’s Privacy & Credit Reporting Policy, which may be found at www.pepper.com.au/privacy-policy.
When we refer to personal information we mean information from which your identity is reasonably apparent. This information may include information or an opinion about you. 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. When you use our website or mobile applications we may collect information about your location or activity including IP address, telephone number and whether you have accessed third party sites, the date and time of visits, the pages that are viewed, information about the device used and other user location information. We collect some of this information using cookies.
If you are applying for finance or provide a guarantee we may also collect the number and ages of your dependants and cohabitants, the length of time at your current address, your employment details and proof of earnings and expenses.
The personal information we hold about you may also include credit-related information. Credit-related information means:
- Credit information, is personal information or an opinion about you that has a bearing on credit that has been provided to you or that you have applied for. This includes your identity: the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information; default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information and publicly available information; and;
- Credit eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.
We use your credit-related information to assess your eligibility to be provided with any finance. Usually, credit-related information is exchanged between credit and finance providers and credit reporting bodies.
Why we collect your personal information
We collect personal information for the purposes of assessing your application for finance and managing that finance, establishing your identity, marketing other products and services to you, conducting direct marketing and to comply with our legal obligations.
How do we collect your personal information?
Where reasonable and practical we will collect your personal information directly from you where you visit our website or lodge a loan enquiry through this web-page. We may collect information about you that is publicly available, for example from public registers or social media, or made available by third parties. We may also collect your personal information from credit reporting bodies, mortgage and finance brokers, employers and other people such as accountants and lawyers. We also collect personal information about you from a credit reporting body as your authorised “access seeker” under Australian Privacy laws.
We will not ask you to supply personal information publicly over Facebook, Twitter, or any other social media platform that we use.
Do we disclose your personal information?
We may disclose your personal information:
- to Pepper Money, to determine if you are eligible for credit with Pepper Money and if so, to provide you with an indicative interest rate, based on the personal information we have provided about you;
- other credit providers and 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, lenders mortgage insurers and credit reporting bodies;
- to associated businesses that may want to market products to you;
- to companies that provide information and infrastructure systems to us;
- to our agents, contractors, external service providers to outsource certain functions, for example, information technology support;
- to any person or entity who represents you, including finance brokers, lawyers, mortgage brokers, guardians, persons holding power of attorney and accountants;
- to any person or entity, where you have provided us consent;
- to our auditors, insurers, re-insurers;
- where we are authorised to do so by law, such as under the Anti-Money Laundering and Counter Terrorism Financing Act 2006 (Cth), government and law enforcement agencies or regulators;
- to investors, agents or advisers, trustees, rating agencies or any entity that has an interest in your finance or our business;
- organisations that provide products or services used or marketed by us.
Credit related information
We exchange credit-related information for the purposes of assisting you deal with credit providers and credit reporting bodied.
This credit-related information may be held by us in electronic form on our secure servers and may also be held in paper form.
When we obtain credit eligibility information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed.
We may from time to time transfer personal information outside Australia in accordance with applicable laws to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws. For example, we may transfer your personal information to the Asia-Pacific, European Union or the United States of America. We may also use cloud storage and IT servers that are located offshore to store the information we hold about you.
By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so, on the basis that (unless otherwise required by law) we are not required to take such steps as are reasonable in the circumstances to ensure that any overseas recipient complies with Australian privacy laws in relation to your information.
The law requires us to advise you of ‘notifiable matters’ in relation to how we may use your credit-related information. You may request to have these notifiable matters (and this policy) provided to you in an alternative form.
We exchange your credit-related information with credit reporting bodies. We use the credit-related information that we exchange with the credit reporting body to confirm your identity, assess your creditworthiness, assess your application for finance or your capacity to be a guarantor and manage your finance.
The information we can exchange includes your identification details, what types of loans you have or have had, how much you have borrowed, whether or not you have met your loan payment obligations and if you have committed a serious credit infringement (such as fraud).
You have the right to request access to the credit-related information that we hold about you and make a request for us to correct that credit-related information if needed. Please see the heading Access and correction to your personal and credit-related information, below.
Sometimes your credit information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers. You can contact the credit reporting body at any time to request that your credit information is not used in this way.
You may contact the credit reporting body to advise them that you believe that you may have been a victim of fraud. For a period of 21 days after the credit reporting body receives your notification the credit reporting body must not use or disclose that credit information. You can contact any of the following credit reporting bodies for more information:
- Equifax Pty Ltd – www.equifax.com.au,
- illion Australia Pty Ltd – www.illion.com.au, or
- Experian Australia Credit Services Pty Ltd – www.experian.com.au.
From time to time we may use your personal information to provide you with current information about finance, offers from Pepper Money and other credit provider that 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. By providing us with your personal information, you consent to us using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone. You also consent to us sharing your personal information with Pepper Money for direct marketing purposes.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting us using the contact details below. 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.
Advertising and Cookies
We use ‘cookies’ to provide you with better and more customised service and with a more effective website.
- to allocate a unique number to your internet browsers;
- to customise our website and offers for you;
- for statistical purposes;
- to identify if you have accessed a third party provider’s website for goods and services; and
- for security purposes.
Your IP address is the identifier for your computer when you are using the internet. It may be necessary for us to collect your IP address for your interaction with various parts of our website.
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 and credit information
We will provide you with access to the personal and credit-related information we hold about you. You may request access to any of the personal information we hold about you at any time. To access personal information that we hold about you, use the contact details specified below. We may charge a fee for our costs of retrieving and supplying the information to you.
There may be situations where we are not required to provide you with access to your personal or credit-related information, for example, if the information relates to existing or anticipated legal proceedings, if your request is vexatious or if the information is commercially sensitive.
An explanation will be provided to you if we deny you access to the personal or credit-related information we hold about you.
If any of the personal or credit-related information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information by contacting us using the contact details below.
If appropriate we will respond to a request to access or 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 or credit-related information within 30 days.
We may need to consult with other finance providers or credit reporting bodies or entities as part of our investigation.
If we refuse to correct personal or credit-related information we will provide you with our reasons for not correcting the information.
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 a range of measures and reasonable steps to protect your personal information. Your personal information will always be stored 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.
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 and the Credit Reporting Code, you may contact our complaints officer on the details bellow.
The Privacy Officer
PEPL Holdings Pty Limited
PO Box 6186
NORTH SYDNEY NSW 2060
Telephone: 1300 650 931
We will acknowledge your complaint within seven days and aim to resolve the complaint as quickly as possible. 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, the Australian Financial Complaints Authority Financial Services Complaints Limited which can be contacted on 1800 931 678 or via their website on www.afca.org.au.
You may request further information about the way we manage your personal or credit-related 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.
As a consequence, we may change this policy from time to time or as the need arises. We will post any changes to this policy on our website.
You may request this policy in an alternative form by contacting the Privacy Officer on the above details.
This privacy and credit reporting policy came into existence on [XX] September 2020. (DATE TO BE FINALISED)