1. About Wunder Pay and this policy

Wunder Pay is committed to protecting the privacy and security of your personal information including your credit information.

In this policy, ‘We’, ‘us’ and ‘our’ refer to Bcent Pty Ltd ABN 61 131 695 504 trading as Wunder Pay.

This policy explains how we protect, collect, store, use and disclose your personal information generally for all our customers, prospective customers, agents, dealers, contractors, suppliers, service providers and employees. In addition, this policy also includes how we how we collect, use, disclose and otherwise manage credit information for all our customers and guarantors.

We are bound by the Privacy Act 1988 (Cth) (Privacy Act), including Part IIIA of the Privacy Act and the Australian Privacy Principles contained in the Privacy Act, as well as the Privacy (Credit Reporting) Code 2014 (CR Code).

Sometimes we update our privacy policy. You can always find the most up-to-date version on our website.

2. What information do we collect?

We collect personal information including credit information.

What is personal information and what kinds of personal information do we collect?

Personal information’ is information about, and which identifies, an individual (such as name and contact details). Personal information we collect may include:

• information about your identity — your name, address, contact details, date of birth, gender, marital status, dependants and occupation;
• Government issued identifiers such as your driver’s licence number, passport or Medicare card;
• Your tax residency status and related information such as your Tax File Number or Tax Identification Number
• financial and transaction information;
• your interactions with us (such as transactions on your account);
• your credit history (including what you borrow, whether you make repayments on time and information obtained from credit reporting bodies (CRBs))
• When you visit our websites or use our mobile apps — your location information, IP address and any third party sites you access. Some of this website information we collect using Cookies (for more information please see Clause 11 – Internet Privacy; and
• employment details.

The personal information we collect about you may also include credit information (which is described further below).

The personal information that we collect about you will depend on the product that you apply for or enquire about. Wunder Pay will only collect personal information that is relevant to your loan or lease application or that is necessary for the ongoing management and administration of your loan or lease.

What is credit information and what kinds of credit information do we collect?

Credit information is personal information that, in broad terms, relates to the credit that has been provided to you or that you have applied for. It includes information supplied to us by a credit reporting body, and any information that we derive from it.

When you apply for a loan or lease, we will obtain a credit report which contains information about your credit history. A credit report contains information which assists us to assess your application, including information about your credit history with other credit providers. Credit reports are designed to assist credit providers to accurately assess an individual’s ability to repay credit.

We also collect other credit information about your financial position including: 

• information about your employment, income and expenses; and
• your dealings with other credit providers, including information about any serious credit infringements that you may have committed.

3. How do we collect personal information (including credit information)?

We usually collect personal information directly from you or from third parties, such as:

• other credit providers or financial institutions such as banks;
• credit reporting bodies;
• any person or body who may provide reports on your commercial activities and your commercial credit worthiness;
• brokers;
• your representatives such as financial advisers, accountants or your insurers;
• your employer;
• publicly available sources of information;
• any local government office or other government authority; and
• any person or body referred to in your loan or lease application.

4. Why we collect personal and credit information 

The main reason we collect, hold and use personal information and credit information is to:

• Confirm your identity;
• manage your loan and related funding arrangements;
• to collect overdue payments, to manage credit, to help you avert default on credit obligations and take action in the event of your fraud or other serious credit infringement;
• for internal processes including risk management and pricing;
• to administer our relationship with you;
• to meet our obligations in relation to external payment, credit reporting systems, Government bodies and our funding arrangements;
• to identify and (unless you tell us not to) tell you about products that may interest you, and to comply with regulatory requirements;
• to contact you and otherwise manage our relationship with you;
• maintain and monitor loans or leases over the term of that loan or lease;
• monitor and evaluate our products and services;
• gather and aggregate information for statistical, prudential, actuarial and research purposes;
• maintain our internal operations, including record keeping, risk management, auditing purposes, transactions, credit scores and file reviews;
• take measures to detect and prevent frauds and credit loss;
• monitor, resolve and prevent complaints you may raise against Wunder Pay or to manage legal action between you and Wunder Pay;
• manage our business;
• assess an application for, or collect overdue payments of, commercial credit;
• consider whether or not to accept you as a guarantor or security provider;
• obtain commercial credit information about you in order to assess an application by you for consumer credit.
• and
• marketing our products and services (as described in the ‘Direct Marketing’ section below).

Direct Marketing

We may use your personal information to let you know about new or existing products or services that we think might be of interest or value to you. We may provide your personal information to third parties that provide direct marketing services for Wunder Pay.

To do this, we may contact you by email, phone, SMS, social media, mail, Wunder Pay and third-party apps or Wunder Pay or third-party websites.

We will not send you direct marketing messages if you inform us that you do not want to receive them. You can opt-out or change your marketing preferences by using the ‘unsubscribe’ facility included in the email.

We keep your credit information with your other personal information. You can view this information or ask us to correct it if it’s wrong or make a complaint to us.

5. What happens if you do not provide us with the information we request?

If you do not provide us with the personal information that we reasonably request, Wunder Pay may be unable to provide you with a loan or to provide other services to you. 

6. Who do we share your information with?

Wunder Pay may share your personal information (including credit information) with people and organisations outside of the Wunder Pay Group where that third party assists in relation to the establishment or administration of your loan or lease or supports the provision of services to you. We only provide these third parties with the information needed to provide the service or comply with the law.

Exchange of personal information generally

The types of third parties that we may share your personal information (including credit information) with include:

• our agents, payment system operators, contractors and contracted service providers such as mailing houses, data processors, technology service providers, researchers and debt collectors;
• specialists who assist us – including legal service providers, insolvency practitioners, accounting and business consultants, real estate agents and valuers;
• Third parties that you have authorised to act for you – including accountants, financial counsellors, legal representatives, agents, brokers, financial advisors, or a person with Power of Attorney
• Third parties who act on behalf of brokers – including broker groups and broker industry associations insurers and re-insurers;
• regulatory bodies, government agencies and authorities, local government offices, courts and external dispute resolution schemes;
• Guarantors, co borrowers, and other security providers;
• Organisations involved in our funding arrangements — like loan purchasers, investors, advisers, researchers, trustees and rating agencies;
• Insurers and their underwriters;
• registers relevant to services we provide, such as the Personal Property Security Register;
• People who help us process claims — like assessors and investigators;
• Other banks and financial institutions — for example, if we need to process a claim for mistaken payment; and
• We may also share your personal information (including credit information) with third parties where:
  • it is permitted or required by the law;
  • you provide your express consent to the disclosure or your consent may be reasonably inferred from the circumstances; or
  • privacy laws otherwise allow us to disclose the information.

Exchange of personal information with CRBs

If you ask us for credit or choose to be a guarantor, we may check your credit reports. We get these from credit reporting bodies.

We also share your credit information with them so they can provide credit reports to others.

A credit report gives us information about your credit history. Credit reports are provided by credit reporting bodies, who collect and share credit information with credit providers like us.

The credit reporting bodies we use are Equifax, Experian Australia Credit Services Pty Ltd and illion.

You can download a copy of their respective privacy policies at:

Equifax — www.equifax.com.au

Experian — www.experian.com.au

illion — www.illion.com.au

Creditor Watch —https://creditorwatch.com.au/privacy/

The Privacy Act limits the information that we can give to credit reporting bodies, and that they can give us. The Act also limits how we can use credit reports.

The information we can share with credit reporting bodies includes:

The information we can share with CRBs include:

• that we provide credit to you;
• the type of credit that you hold;
• how much credit we have provided to you;
• the terms and conditions of the provision of that credit;
• when your credit account is opened and closed;
• how you repay your credit;
• if you have failed to meet your repayment obligations or default on your obligations;
• if you have committed a serious credit infringement;
• if you make repayments on time; and
• if you correct a default.

In order to verify your identity, we may provide your name, residential address and date of birth to a CRB, which may use that information and corresponding information in credit information files of individuals to prepare and provide an assessment of whether your information matches information on a credit information file held by that CRB.

Exchange of personal information with credit providers

We may exchange your personal information with other credit providers (including information provided by or derived from a CRB such as a consumer credit report) for purposes permitted by Law including but not limited to the purposes described above.

Exchange of personal information with guarantors

If you are a borrower or hirer, we may exchange your personal information (including a consumer credit report) with your guarantor, a person who has provided security for credit, or to a person in order for them to consider whether or not to act as guarantor or to provide security for credit.

7. Protecting your Information

Your personal information (including credit-information) is kept in both hard copy and electronic form. We may use cloud storage to store the personal information we hold about you.

The electronic information is stored in secure monitored storage areas located in Australia (including storage areas owned and operated by our contracted service providers).

We use a range of security measures to protect the security and confidentiality of your personal information. These measures include the following:

• .When we no longer require your personal information (and are no longer required by law to keep it) we take reasonable steps to destroy or permanently de-identify it.

Although we take reasonable measures to protect your personal information, no data transmission over the internet can be guaranteed to be fully secure. Please contact us immediately if you think that your interaction with us is no longer secure.

Overseas Disclosures

Some of the parties with which we share your personal information (including credit information), such as our contracted service providers, are located or operate outside of Australia. It is not practicable to list every country in which such recipients are located but it is likely that such countries will include the Philippines, India and Nepal.

Where we send information overseas, we ensure there are arrangements in place to protect your information. 

8.  Accessing and seeking correction of your information

We take reasonable steps to make sure that the personal information (including credit information) that we collect, use or disclose is accurate, complete and up to date.

You can request access to and ask that we correct the personal information (including credit information) we hold about you.

There is no fee for requesting a correction to your personal information or for us to make corrections. There may be a reasonable charge for giving you access to your personal information to cover our costs for locating and giving this information to you (but there is no fee for simply making the request).

If you have requested access to your personal information, the Privacy Officer will then contact you to advise you of the timeframe for collecting or viewing your personal information and any associated fee (which must be paid before the information is provided to you).

In some cases, we can refuse access or only give you access to certain information. For example, we might not let you see information that is commercially sensitive, or it is information that involves other people.

If we do this, we’ll write to you explaining our decision.

If we refuse to give you access to or to correct your personal information, we will give you a notice:

• explaining the reasons for our refusal (except where it would be unreasonable for us to do so); and
• providing information about how you can complain about the refusal.

If we don’t think the information needs correcting, we’ll write to let you know why. You can ask us to include a statement with the information that says you believe it’s inaccurate, incomplete, misleading or out of date.

If you believe that any personal or credit information that Wunder Pay holds about you is not accurate, complete or up to date, you should notify the Privacy Officer in writing as soon as possible.

9. Making a privacy complaint

If you have a concern or complaint about your privacy, let us know and we’ll try to fix it. If you’re not satisfied with how we handle your complaint, there are other things you can do.

Credit information complaints

If your complaint is about your credit information, we may need to check with credit reporting bodies or the credit provider involved. We will let you know we have received your complaint within seven days of receipt of your complaint. If we cannot resolve your complaint within 30 days, we will get in touch to tell you why and agree a new timeframe with you.

What else can you do?

If you are not satisfied with how we have managed your complaint or our decision after you have been through our internal complaints process, the Australian Financial Complaints Authority (AFCA) offers a free independent dispute resolution service for consumer and small business complaints. Before AFCA can investigate your complaint, they generally require you to have first provided us with the opportunity to address the complaint (see the section titled ‘Making a privacy complaint’ for details of how you can lodge your complaint with Wunder Pay).

You can contact AFCA between 9am and 5pm (Sydney time) Monday to Friday using the contact details set out below.

AFCA can consider most complaints involving financial services providers.

If your complaint is about how we handle your personal information, you can also contact the Office of the Australian Information Commissioner (OAIC) using the contact details set out below. The OAIC requires you to first make your complaint to us. We have 30 days to deal with your complaint before you are able to make a complaint to the OAIC.

 

Australian Financial Complaints Authority

GPO Box 3

Melbourne VIC 3001

Phone 1800 931 678 (free call)

Email info@afca.org.au

Visit afca.org.au

 

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

Phone 1300 363 992

Email enquiries@oaic.gov.au

Visit oaic.gov.au

10. We are here to help

If you want to update your personal information, or if you have a privacy concern or complaint, need more information, you can contact Wunder Pay by:

Contact: The Privacy Officer

Postal address: Level 3, 3-5 Bennett Street East Perth WA 6004

Email address: admin@wunderpay.com.au

Telephone: [TBA]

11. Internet Privacy

In addition to the above Privacy policy, this section further explains the management of personal information collected through your use of the Wunder Pay website. When you use this website our Internet Service Provider (ISP) may make a record of your visit and log your server address, your domain name, the date, time and duration of your visit, the pages and documents you accessed, the previous site you had accessed (ie the referring url) and the type of browser you are using.

It is possible that your ISP is logging your activity while you visit our site. This is obviously beyond our control.

Cookies

While you are visiting our site we may use cookies. Cookies do not identify you personally, but they may link back to a database record containing personal information about you. You can set your browser to accept or reject cookies, or to notify you whenever cookies are created so that you can decide each time whether to accept them. If you set your browser to reject cookies from our site, your ability to use our site may be limited as certain features may not function correctly. The main purpose of cookies is to identify users (using their IP address) and to facilitate a more personalised web browsing experience.

We also use advertising cookies to collect anonymous data (including users’ demographics and interests), which we may provide to third party vendors such as Google or Salesforce as part of our implementation of some advertising activities, including in connection with Google Analytics.

We and our third party vendors use first party cookies or other first party identifiers, and third party cookies or other third party identifiers, to optimise and serve advertisements to you and to analyse your interaction with advertisements.

We expressly exclude any responsibility for any act or omission of these entities and their collection and use of your cookies and other data.

The Wunder Pay website contains links to websites of third party providers of goods and services. Such websites should contain their own privacy statements and we are not responsible for the privacy practices or content of any websites linked to this website.