Privacy Policy

Version: 14th of May 2015

 

Central to the success of Lucrum Equity privacy is our commitment to our clients. We honour without reservation our obligation to respect and protect the privacy of the personal information of individuals and organisations with whom we deal.

 

This policy is intended to help you understand how Lucrum Equity manages the personal, credit, organisational and their related entities information and records that we collect, hold, use and disclose, how you can seek access to and correction of that information and, if necessary, how you can make a complaint relating to our handling of that information. 

 

We are serious about our responsibility to protect your personal, organisational and credit information and manage it consistently with the Privacy Act and Credit Reporting Code. Lucrum Equity in Australia is committed to maintaining the privacy of our clients. Unless stated otherwise, this policy is relevant to the personal and credit information of both our current and former clients, as well as other individuals we may deal with (for example, guarantors, directors and shareholders relating to our clients, or individuals we deal with in other capacities as part of our business).

 

This policy also includes our credit reporting policy, it covers additional information on how we manage your personal or organisations and related entities information collected in connection with a credit application or a credit facility. We refer to this credit-related information in this policy as credit information.

 

This Policy explains

1. the kinds of credit, credit eligibility, personal, organisational & related entity information that we collect and hold;

2. how we collect and hold credit, credit eligibility, personal, organisational & related entity information;

3. the purposes for which we collect, hold, use and disclose credit, credit eligibility, personal, organisational & related entity information;

4. how you may access your credit, credit eligibility, personal, organisational & related entity information held by us or request correction of that information;

5. how to make a complaint if you consider that we have not complied with Part IIIA of the Privacy Act or with the Credit Reporting Privacy Code, and how we will deal with such complaints; and

6. the circumstances in which we may disclose credit, credit eligibility, personal, organisational & related entity information to overseas recipients and the countries where such recipients may be located.

 

The information we collect and hold

Whenever it is reasonable and practical to do so, we collect information about you directly from you. In some cases, we collect personal information from third parties including public sources, our related companies, referrers, brokers, agents, your adviser(s) and our service providers including credit reporting bodies and information service providers.

 

We collect personal information about you which is reasonably necessary to:

1. provide you with quality products or services.

2. consider applications and approaches you make to us.

3. maintain your contact details.

 

We generally hold personal information relating to:

4. fulfil our legal obligations under applicable laws and rules, such as those relating to taxation and Anti-Money Laundering and Counter-Terrorism Financing.

1. the products and services we provide or have provided to you.

2. your financial interests and your financial position, if you are a customer or potential customer of ours.

3. your name, contact details and identification information.

4. records of our interactions with you, including by telephone, email and online.

5. your enquiries or complaints.

 

What types of information do we collect and hold:

The personal information we collect and how we do so will vary based on why we are collecting the information, for example, if you are a client it will depend on the product or service we are providing. Information we collect may include:

1. Information collected on application forms, questionnaires or other documentation or communications, such as your name, date of birth, residential and business addresses, telephone numbers, email and other electronic addresses,

occupation, assets, expense, income, dependents and details about your business dealings and other events in your life;

2. Information about your transactions and products with us, our affiliates, or third parties, such as account balances, payment history and details about account activity and product use;

3. Unless required by law, we will only collect sensitive information with your consent; Sensitive information, including professional associations (e.g. you provide to us so that we can conduct an investment suitability assessment); membership of political associations or health information. 

4. Government identifiers such as your driving license number, ABN/ACN or passport number (for example, to

verify your identity at the time you request a product or service); and

5. Other information we think is necessary to your relationship with us.

In addition, all of our websites use a standard technology called "cookies" to collect information about how our websites are used, which may include your personal information. The use of cookies is essential to the operation of our websites. You may opt-out of receiving cookies by disabling cookie support but doing so may prevent our websites from functioning properly and you may not be able to use fully all of their features and information.

We do not generally collect sensitive information about you unless required by applicable laws or rules. Sensitive information includes information

relating to:

1. race

2. political or religious beliefs.

3. sexual preferences.

4. criminal convictions.

5. Tax File Numbers (TFNs).

6. health information.

We may collect information about your affiliation with certain organisations such as professional associations.

 

Purposes for which we may collect, use and disclose your information

If you are applying for credit or you have obtained credit from us or if you guarantee or are considering guaranteeing the obligations of another person to us or you are a director of a company that is a loan applicant or borrower or guarantor we may collect, use and disclose your credit information for purposes including:

1. To form decisions as to whether to provide you, or an entity associated with you, with credit or to accept you as a guarantor;

2. provide you with quality products or services consider applications and approaches you make to us;

3. To derive scores (a calculation that lets us know how likely you will repay the credit we make available to you), ratings, summaries and evaluations relating to your credit worthiness which are used in our decision-making processes and ongoing reviews;

 

Disclosure of personal information to third parties

4. To manage credit we may provide, including to determine whether you are eligible to receive particular offers and invitations and to develop our services and maintain and develop our systems and infrastructure;

5. To assist you to avoid defaulting on your credit-related obligations;

6. To deal with complaints and to assist other credit providers to do the same; and

7. To meet legal and regulatory requirements.

8. Disclosure to third parties.

We receive services from other companies and external service providers, some of which may be located outside of Australia (see the additional section below titled "Overseas Disclosures" for more information), and your information may be provided to them for this purpose. We may also disclose your personal information to other Lucrum Equity entities and to third parties for the purposes listed above.

Third parties to whom we disclose your personal information may include:

1. Our related Lucrum Equity companies in Australia and joint venture partners that conduct business with us;

2. Any person to whom disclosure of your personal information is necessary in order for us to validly provide,

manage, administer and/or enforce any services or transactions requested or authorized by you including:

a. administrative service providers, such as mailing houses, printers and call centre operators;

b. custodian; registry and agents or brokers to whom we delegate any of our duties, functions or obligations under any of our agreements with you;

c. any person with whom we enter into any contractual or other arrangement in relation to any of the services and facilities we provide or propose to provide to you including any guarantors, sureties, third party security providers and/or third party service providers.

d. participants in financial and payment systems, such as other banks, credit providers and clearing entities;

e. organisations that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems.

3. Legal, audit, settlement and valuation and any other professional service providers under a duty of confidentiality to us;

4. Data processing and market research service providers who provide marketing, market research, or other related services to us in connection with the development and promotion of our business;

5. Regulatory bodies in Australia and overseas including ASX Limited where required under the ASX Operating Rules. ASX Limited may use your personal information for its own purposes including in the course of compliance activities;

6. Financial and other advisors, brokers and distributors who provide introducing services to us or to whom we provide introductions or referrals;

7. Insurers, assessors and underwriters;

8. Your guarantors and security providers;

9. Any financial institutions, finance underwriters & other credit providers as specified for the collection purpose;

10. Debt collectors or any person in connection with any claims involving you in respect of any products and/or services provided by us;

11. Government or regulatory bodies (including ASIC and the ATO) as required or authorized by law (in some instances these bodies may share information with relevant foreign authorities);

12. Fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime or misconduct of a serious nature);

13. Organisations wishing to acquire an interest in any part of our business from time to time; and

14. Any person to whom we are under an obligation to make disclosure under the requirements of any law, rules, regulations, codes of practice, guidelines or voluntary.

 

Disclosure of credit information to third parties

arrangements binding on us including, any applicable regulators, governmental bodies or industry recognized bodies such as future exchanges, fiscal and monetary authorities, securities exchanges (all of which may be within or outside of Australia) and where otherwise required by law, including, without limitation , to any tax authority of any jurisdiction or where we have reason to believe you may be a resident for tax purposes, citizen or otherwise subject to tax.

15. Where you have given your consent. We do not usually access credit information directly from credit reporting bureau  CRB) however in some circumstances as directed by you this section explains the information we used or access for the purposes listed above and access to the information to indicate a related third party Lucrum Equity have associations with is assumed to access this type of information to complete the transaction for products and services requested.

We may as permitted by law and to in the normal course of providing products and services also share credit information with third parties, including:

1. Other credit providers;

2. Our related companies;

3. Organisations that perform credit assessment, management and debt collection activities on our behalf;

4. Current or prospective guarantors or security providers in relation to credit we are providing to you;

In some circumstances we may require your consent before being able to make such disclosures.

 

Holding and protecting your personal and credit information

 

5. Lending institutions involved in sourcing the appropriate options for credit you may engage in at your discretion;

6. Mortgage insurers;

7. Organisations involved in debt assignment;

8. Our external dispute resolution scheme.

Your personal and credit information may be held in physical or electronic form (including cloud also see overseas disclosures) on our systems or the systems of our service providers and is protected by physical, electronic and procedural safeguards. We apply a need to know/need to have policy which means that individuals are only given access to the information that they require in order to perform their duties. We also require our service providers to follow appropriate standards of confidentiality and security when holding and processing your information.

 

Overseas Disclosures

Some of the above recipients of personal or credit information may be located outside of Australia. It is not reasonably practicable to list all of the countries to which your information may be transmitted from time to time.

We may store your information in various types of networked or electronic storage (including cloud). As these storage methods can be accessed from various countries via an internet connection it is not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.

Overseas organisations may be required to disclose information we share with them under a foreign law.

We will not share your credit information with a CRB, unless it has a business operation in Australia.

We are not likely to share credit information we obtain from a CRB or that we derive from that information with third parties unless they have business operations in Australia. We will, however, share credit information with our related companies. We are likely to share other credit information with organisations outside of Australia for the limited purposes of managing your credit information or for debt collection. When we do so, we remain responsible for that disclosure and will ensure that your credit information is handled according to the requirements under the Part IIIA of the Privacy Act.

 

How can you make a complaint about our compliance with our credit reporting obligations and how will we deal with such a complaint

If you believe that we have failed to comply with the credit reporting requirements in Part IIIA of the Privacy Act or the Credit Reporting Privacy Code, please contact us and we will then follow our Internal Dispute Resolution process. The 'Contact Us' section of our website contains details of the ways you can contact us.

How you may access your personal information held by us and correct that information where it is incorrect you are entitled to access the information we hold about you. Simple requests are best handled by speaking to the relevant customer service area. More complex requests may be better detailed in writing to ensure we fully understand and are able to respond accurately to your request. The 'Contact Us' section of our website contains details of the ways you can contact us.

If there is a reason, we are unable to agree to a request for access to your personal information we will advise you of this in writing. Some examples of why we may refuse a request for access include, where providing the information:

1. may pose a threat to the health or safety of an individual or the public;

2. may have an unreasonable impact on the privacy of another individual;

3. is not allowed by law; or

4. may reveal internal information relating to a commercially sensitive decision making process.

If information we hold about you is incorrect we would like to know so that we can promptly correct this. The 'Contact Us' section of our website contains details of the ways you can contact us and request a correction.

In certain situations, we may not agree to a request to correct information we hold about you, if this occurs we will advise you of this and our reason for not agreeing to the correction request.

How you may make a complaint about the way we collect, hold, use or disclose personal information and how we will deal with Privacy related complaints.

If you want to make a complaint about our handling of personal information we ask that you contact us first. We will then follow our Internal Dispute Resolution (IDR) process. The 'Contact Us' section of our website contains details of the ways you can contact us.

 

Blogs, forums, wikis, and other social media

This Website may host various blogs, forums, wikis, and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal information or other information that you contribute to any Social Media Application can be read, collected, and used by other users of that Social Media Application over whom we have little or no control. Therefore, we are not responsible for any other user’s use, misuse, or isappropriation of any personal information or other information that you contribute to any Social Media Application.

 

Information security

We have in place reasonable commercial standards of technology and operational security to protect all information provided by visitors via this Website from unauthorized access, disclosure, alteration, or destruction. The security standards are periodically reviewed to ensure the security standards comply and are up to date with the relevant laws affecting this privacy act & other applicable laws.

 

Direct Marketing

Personal information may also be used or disclosed to advise you of products and services that may be of interest to you by means of direct marketing.

If you do not want your personal information to be used for direct marketing purposes please contact us so that we can action this request. This is referred to as "opting out" of direct marketing. You can "opt-out" of direct marketing using the details in the 'Contact Us' section of our website.

 

Changes to our Privacy Statement

We may modify or amend this Privacy Statement from time to time at our discretion. When we make changes to this Statement, we will amend the revision date at the top of this page, and such modified or amended Privacy Statement shall be effective as to you and your information as of that revision date. We encourage you to periodically review this Privacy Statement to be informed about how we are protecting your information.