Privacy & Cookie Policy – AUS
Last edited: 26.04.23
This Privacy Policy covers Payleadr Pty Ltd ACN 615 881 162, trading as aglow (us, we or our).
We understand that the privacy of your personal information is important to you. This Privacy Policy explains how we handle your personal information and credit information.
By providing your personal or credit information to us, you consent to us collecting, using and disclosing your personal and/or credit information in accordance with this Privacy Policy.
We may change this Privacy Policy from time to time by publishing changes to it on our website. Please check our website regularly to ensure that you are aware of any changes to this Privacy Policy.
What is personal and credit information?
Personal information is information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, email address and contact details.
Credit information is personal information that is collected in connection with a credit application. For example, this may include your identification information, default information or repayment history information.
What personal and/or credit information do we collect?
The information we may collect from you and hold includes:
- Identity information – such as your name, date of birth, gender and identification document information (for example, your drivers’ licence, passport or proof of age card details).
- Contact information – such as your residential or postal address, email address and telephone numbers.
- Financial details – such as your credit card or bank account details.
- Credit information – such as type and amount of credit sought, payment information, default information, repayment history and new arrangement information (if the terms of repayment have changed).
- Other personal information such as details of your interactions with us.
We may collect these types of information either directly from you or from third parties. We may collect information when you:
- Use our website;
- Communicate with us through phone calls, correspondence, email or when you share information with us from other social applications, services or websites;
- Complete an Application Form to apply to receive our services; Enter or exchange details through the Payleadr Platform;
- Use software or other applications that integrate with the Payleadr Platform;
- Complete a Direct Debit Request Form.
We may collect information about you from third parties such as:
- Credit reporting bodies;
- Service providers that offer identity verification services; and
- Your financial institution.
Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal and credit information for the following purposes:
- To provide you with information about our products and services;
- To provide, manage and administer our products and services;
- To assess applications for our products and services, including eligibility for any of our products and services or particular features;
- To enable us to establish your identity and the accuracy of the information you have provided to us
- To send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- To send you marketing and promotional messages and other information that may be of interest to you;
- To enable us to identify and monitor suspicious or fraudulent activity in relation to our products and services;
- To enable you to access and use our website and services; any other purpose consented to by you;
- To enforce your compliance with our terms and conditions;
- To comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
- For any purpose related to the above.
If you do not provide us with the personal or credit information we request, we may not be able to provide you with the services you have requested.
Do we use your personal information for direct marketing?
We may send you direct marketing communications and information about our services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting the Privacy Officer using the contact details set out below or by using the opt-out facility provided in the relevant direct marketing communication (eg an unsubscribe link).
To whom do we disclose your personal information?
We may disclose personal and credit information for the purposes described in this Privacy Policy to:
- third party suppliers and service providers (including providers for the operation of our platform and cloud service providers);
- your bank or financial institution or other financial institutions involved in the payment process;
- the other parties to a payment plan that you have entered into;
- providers of any integrated software products;
- debt collection agencies;
- our representatives and advisors, including lawyers and accountants;
- specific third parties authorised by you to receive information held by us; and
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
We may share your information with third parties that we have partnered with. Generally, the information that we will share with these third parties will be aggregated or anonymised information. However, we may disclose some personal information to these third parties. These third parties may use the information to improve their existing products/services and to provide you with direct marketing material about the products or services that they could provide to you. If you do not wish for us to pass on your personal information to our third party partners for the purposes of that third party sending you direct marketing material, please let us know by contacting the Privacy Officer using the contact details set out below.
Sharing (disclosing) your information outside Australia
We share (disclose) personal information outside of Australia to Snowflake (https://www.snowflake.com), a cloud based data platform, which is located in the United States of America.
Using our website and cookies
We may collect personal information about you when you use and access our website. While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
How do we keep your information safe?
We may hold your personal and credit information in either electronic or hard copy form. We take reasonable steps to protect your information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example we:
- train our staff about how to keep your information safe and secure;
- have firewalls, intrusion detection and virus scanning tools to stop viruses and unauthorised access to our systems;
- imposing confidentiality restrictions on our staff;
- have building security measures in place;
- destroy and de-identify data when it is no longer required.
However, we cannot guarantee the security of your information.
Links
Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.
Accessing or correcting your information
You can request access to, or correction of, the personal and credit information we hold about you by contacting the Privacy Officer using the contact details set out below. Sometimes, we may not be able to provide you with access to all of your information or make the correction you have sought. Where this is the case, we will provide you with a written response setting out why we have not been able to action your request. We may also need to verify your identity before we action any request for access or correction of your information.
Do we disclose information to credit reporting bodies?
We may disclose your personal or credit information to a credit reporting body for the purposes of:
- undertaking a credit check in relation to an application made by
- you or assessing your eligibility for our products and services;
- verifying your identity in accordance with our customer due diligence obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth);
- managing any credit provided by us;
- collecting payments that are overdue in relation to any credit provided, including under the terms of a payment plan entered into by you; and
- disclosing payment default information in relation to any credit provided, including under the terms of a payment plan entered into by you.
We may disclose information to or collect information from the following credit reporting bodies: Equifax Australia Website:
Equifax Australia
Website: www.equifax.com.au(please refer to the website for their privacy policy)
Phone: 13 8332
Equifax may include any of your personal or credit information, disclosed to it by us, in reports provided to other credit providers to assist other credit providers to assess your credit worthiness.
You should be aware that if you fail to meet any of your payment obligations or you commit a serious credit infringement, we may be entitled to disclose this to the credit reporting body. You have the right to make a request to Equifax not to use or disclose your credit reporting information:
- for the purposes of pre-screening of direct marketing by a credit provider; or
- if you believe on reasonable grounds that you have been, or are likely to be, a victim of fraud.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal or credit information, you can contact the Privacy Officer using the contact details set out below.
Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
If you are not satisfied with how we have dealt with your complaint you can contact the Office of the Australian Information Commissioner using any of the following details:
GPO Box 5218
Sydney
NSW 2001
Phone: 1300 363 992
www.oaic.gov.au
Contact Us
For further information about our Privacy Policy or practices, or to access or correct your information, or make a complaint, please contact our Privacy Officer using the details set out below: